Earlier this week, CMS posted a notice on its website granting a 31-day extension to IPPS hospitals in Texas, Louisiana, Florida, Georgia, South Carolina, Puerto Rico and the U.S. Virgin Islands to submit FFY 2014 and FFY 2015 Worksheet S-10's. This comes on the heels of Hurricane Harvey, Irma and Maria, the President declaring a state of emergency and the HHS Secretary declaring a public health emergency for Texas, Louisiana, Florida, Georgia, South Carolina, Puerto Rico and the U.S. Virgin Islands. Both the President and HHS Secretary's actions allow CMS to put in place programmatic waivers based on Section 1135 of the Social Security Act.
On June 30, 2017, CMS released Transmittal 1863 (beginning on page 2), which included, among other items, guidance for MACs to follow for accepting cost reports containing revised Worksheet S-10 information. Similar to 2016's Transmittal 1681, in order for MACs to accept amended cost reports due to revisions to Worksheet S-10 for FY 2015, CMS has put providers on notice by stating that “hospitals must submit their amended cost report containing the revised Worksheet S-10…no later than September 30, 2017.” Then on July 13, 2017, CMS announced that “amended FY 2014 cost reports due to revised or initial submissions of Worksheet S-10 received by Medicare Administrative Contractors on or before September 30, 2017, will be uploaded to the Healthcare Cost Report Information System by December 2017”. With the 31-day extension from this week's notice, IPPS hospitals in Florida, Georgia, South Carolina, Puerto Rico and the U.S. Virgin Islands who wish to submit initial or revised FFY 2014 and/or FFY 2015 cost report Worksheet S-10's, now have until October 31, 2017.
Per the FY 2018 IPPS final rule, cost report Worksheet S-10 will now be used in calculating a qualifying provider's Factor 3 for the uncompensated care distribution payment using the following combination:
1st Factor 3: FY 2012 cost report low-income days and FY 2014 SSI days
2nd Factor 3: FY 2013 cost report low-income days and FY 2015 SSI days
3rd Factor 3: FY 2014 Uncompensated care cost per Worksheet S-10
CMS has stated they would expect a similar methodology to be proposed for FY 2019 (rolled forward one year) and then potentially rolled forward again another year for FY 2020. This means, FY 2014 Worksheet S-10 uncompensated care costs could potentially be used to calculate a provider's Factor 3 for FY 2018, FY 2019 and FY 2020 and FY 2015 Worksheet S-10 data could be used to calculate a provider's Factor 3 in FY 2019, FY 2020 and FY 2021.
As we have stated before, we would suggest that you pay particular attention to if you are audit ready? For the first time, CMS stated in the 2018 final rule, "WE EXPECT COST REPORTS BEGINNING IN FY 2014, FY 2015, AND FY 2016, TO BE SUBJECT TO FURTHER SCRUTINY AFTER SUBMISSION." If you aren’t audit ready with the data you previously submitted, we definitely recommend that you update that information with audit ready support. See our other recommendations in this post, 2018 IPPS Final Rule: "What To Do Now" Recommendations.
We are in the process of wrapping up 106 cost report Worksheet S-10 engagements by the FY 2014 & FY 2015 original deadline of September 30, 2017 for our clients. In the coming weeks, we will focus on a series of posts based on what we've learned from those 106 engagements and the 233 total Worksheet S-10 engagements we have completed since CMS first proposed the eventual use of Worksheet S-10 in the DSH/UC reimbursement formula. All we can say for now is that our clients are quickly finding that there is no “software solution” to compile, analyze, and submit accurate and compliant S-10 data, and that expertise and heavy lifting are necessary. Don't miss this series by subscribing to our blog!
