As you will recall from the FY 2019 IPPS final rule-making cycle, CMS issued new requirements for supporting documentation that must be submitted along with the Medicare cost report. While that final rule was posted a little over a year ago, hospitals will soon be in the midst of filing the first affected cost reports. The new Medicare cost report supporting documentation is required for cost reporting periods beginning on or after October 1, 2018.
The FY 2020 Inpatient Prospective Payment System (IPPS) Final Rule was put on display for public inspection on August 2, 2019, and is scheduled to be published in the Federal Register on August 16, 2019. The pre-publication version can be viewed HERE or on the FY 2020 IPPS Final Rule homepage. These changes will go into effect October 1, 2019.
We began hearing from our client hospitals a few weeks ago that the MAC audits of Worksheet S-10 were starting for FFY 2017. Yes, that’s right, reviews of FFY 2015 data are over and we are onto round 2. We've heard that roughly 600 hospitals will be audited this time around, although we suspect that number is higher based on the audit count we've seen on behalf of our clients and other providers that have contacted SCA. Several hospitals that were selected for FFY 2015 S-10 audits were also selected for FFY 2017 but there have also been a good amount of first-timers in the 2017 S-10 audit pool. So far, the 32 S-10 MAC audit letter requests we’ve seen (5 different MACs) essentially mirror the initial requests for data for FFY 2015, with a few exceptions. This post will review the elements of the S-10 2017 audit letter but to get everyone up to speed on how we got here, we will start with a brief review.
The 2020 IPPS Proposed Rule was published in the Federal Register back in May and public comments were accepted up until June 24. We anticipate that the FY 2020 IPPS Final Rule will be published in early August (perhaps as early as this week) and any changes will go into effect October 1, 2019. In advance of the Final Rule, we thought it would be helpful to review the Medicare DSH/Uncompensated Care payment portions (pages 19406-19423 in the Federal Register) of the proposed rule as it will affect qualifying DSH hospitals.
Southwest Consulting Associates was featured in the latest issue of the First Illinois Speaks HFMA chapter magazine. Beginning on page 12, Kyle Pennington briefly reviews the FY 2020 IPPS proposed rule, summarizes the inaugural audits of 2015 Medicare cost report Worksheet S-10 data and what's coming up next for hospital providers and their reimbursement teams. We’ve also included a post-article update at the end of this post.
The FY 2020 Inpatient Prospective Payment System (IPPS) Proposed Rule was put on display for public inspection on April 23, 2019, and is scheduled to be published in the Federal Register on May 3, 2019. The pre-publication version can be viewed HERE or on the FY 2020 IPPS Proposed Rule homepage. If finalized, these changes will go into effect October 1, 2019. All public comments to the proposed rule are to be received by 5 pm EST on Monday, June 24, 2019.
On April 8, 2019, SCA was provided multiple copies of a MAC letter informing hospitals of potentially aberrant data reported on Worksheet S-10 for federal FY 2017. While we have only seen a few letters to date, it is our understanding that this is a CMS initiative affecting many hospitals. Here is what we have been told at this point:
Southwest Consulting Associates recently participated in a segment of the THA SOLUTIONS Podcast where SCA President Michael Newell discussed the Medicare cost report Worksheet S-10 with Texas Hospital Association's Lance Lunsford. The sixteen minute conversation was part of the podcast segment titled, "Maintain Compliance to Maximize Hospital Funding" and can be heard in its entirety by selecting the play button located at the end of this post.
Hospitals nationwide have been undergoing Worksheet S-10 “reviews” for FY 2015 that in large part culminated at the end of January 2019. Since then, there has been word that additional technical direction was provided to MACs by CMS (not yet shared with hospitals) that addresses how to apply some “findings” from those reviews. Even though the current audit process has not been fully completed, there is much to learn about what has transpired so far and how that may impact future reviews or even future changes to cost reporting instructions.
Last Fall, CMS made updates to the cost reporting software and the rules for filing a hospital Medicare cost report. Additionally, there were new and noteworthy changes included in the FY 2019 IPPS Final Rule. Specifically, the FY 2019 Final IPPS rule included new requirements for cost reports submissions with periods beginning on or after 10/1/2018. Providers must now submit both Worksheet S-10 and Medicare DSH patient level detail along with their cost report submissions.