The Centers for Medicare and Medicaid Services (CMS) has posted a Questions and Answers document providing clarification related to Medicare Cost Report Worksheet S-10. If you’ll recall, CMS issued Transmittal 11 in September 2017 that made a number of revisions to the instructions for reporting data on cost report Worksheet S-10.
Hospital providers had to move quickly to interpret the revisions and incorporate them into their FFY 2014 & FFY 2015 Worksheet S-10 revisions due for MAC submission by January 2, 2018. For those providers who were able to amend and submit timely to the MAC, Transmittal 1981 states that the MACs will upload the FY 2014 and/or FY 2015 revised cost report to HCRIS on or before January 31, 2018. CMS received numerous requests for clarification from the provider community following publication of the FY 2018 IPPS Final Rule and the subsequent issuance of revised cost report instructions, and the Q&A recently posted by CMS provides 20 examples related specifically to Worksheet S-10 for hospital providers to consider.
We will be diving deep into these Q&A’s, and in the coming weeks, we’ll provide further commentary and some actual case studies from our experiences in reviewing, analyzing, and completing 172 fiscal years of S-10 data reviews in-time for the January 2nd deadline alone.
And, now that CMS’ final, final deadline has come and gone to amend FFY 2014 & 2015 cost report Worksheet S-10 data, IPPS hospital providers should plan to evaluate their Uncompensated Care Compliance Programs for FFY 2016 and future cost reporting periods.
If history repeats itself, CMS will likely provide hospitals an opportunity to amend Worksheet S-10 data for FFY 2016 during this year (care to place any bets?). Remember…
- CMS historically provides hospitals only about 90-days notice to revise S-10 data and submit amended cost reports,
- FFY 2016 S-10 data will be used to calculate 1/3 of hospitals’ Uncompensated Care Factor 3 reimbursement beginning in FFY 2020, and
- Many hospitals have filed, or soon will file, their FFY 2017 cost reports, which are scheduled to be the first reports targeted by CMS for MAC audits and desk reviews.
Upcoming Webinar Alert:
We are planning our next webinar “10 Things We’ve Learned from Completing 204 Worksheet S-10 Reviews” to be presented in February. Please take an opportunity to "Save Your Seat" below. Once the date is set, we’ll send you notification so you can finalize plans to attend.