Last week, September 29, 2017, CMS issued Transmittal 11 that makes a number of revisions to the instructions for reporting data on cost report Worksheet S-10. These instructions need to be incorporated into any FFY 2014 & FFY 2015 Worksheet S-10 revisions providers are working to submit by the October 31, 2017 deadline and then for any future year submissions. In particular, the changes include:
Revised instructions for line 20 for subsection (d) Puerto Rico hospitals, charity care and uninsured discounts.
Modified the calculation and clarified the instructions on line 21, column 2, for insured patients and non-covered charges for insured patients for days exceeding a length-of-stay limit.
Clarified the instructions for line 22.
Clarified that the amount reported on line 26 is net of recoveries.
Added line 27.01 to capture Medicare allowable bad debt for the entire facility.
Modified the instructions for line 28 to only capture the non-Medicare bad debt expense.
Modified the calculation for line 29.
Of particular note, the instructions now definitively clarify that “full or partial discounts given to uninsured patients who meet the hospital’s charity care policy or financial assistance policy/uninsured discount policy (hereinafter referred to as Financial Assistance Policy or FAP) may be included on line 20, column 1 of Worksheet S-10.”
In addition to the change in reporting uninsured charity/financial assistance dollars on line 20, CMS is also making changes to other lines as follows:
Include on line 20 column 1, non-covered services for patients eligible for Medicaid or other indigent care programs per hospital policies. This excludes non-covered charges for days exceeding the length-of-stay limit for Medicaid or other indigent care programs as these charges are to be reported in column 2.
The instructions for line 22 clarify what payments should be reported related to both uninsured and insured charity. The instructions differ, as do the instructions for charity care charges on line 20, for cost reporting periods beginning before/after October 1, 2016.
The CCR is no longer applicable to deductible/coinsurance amounts for insured patients approved for charity or non-reimbursed Medicare Bad Debts.
Be sure to review Transmittal 11 and MLN Matters Number SE17031 in full. Again, these updated Worksheet S-10 cost reporting instructions will need to be incorporated into any FFY 2014 & FFY 2015 Worksheet S-10 revisions providers are working to submit by the October 31, 2017 extended deadline and then for any future year submissions.
Hospitals should also pay particular attention to if your Worksheet S-10 data is audit ready. 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." This statement coupled with clarified instructions via Transmittal 11 and current HITECH audit requirements (more on this later) should signal that it is more important than ever to have patient detail to support the data reported on Worksheet S-10. If you aren’t audit ready with the data you previously submitted, we definitely recommend that you update that information with audit ready support.
Do you think that the 31-day extension (October 31, 2017 deadline) allows enough time for providers to make the required adjustments per Transmittal 11? What challenges do you see your hospital encountering with the updated instructions? Let us know in the comments.
