In anticipation of the upcoming 2017 IPPS proposed rule (usually put on display in mid-April), SCA has been focusing our attention on the possible changes to the Uncompensated Care (UC) reimbursement program. Use as your backdrop the following facts:
The 2016 uncompensated care pool (UCP) is $6.4 billion and all “eligible” hospitals are fighting for a piece of that pie.
If the most recent filed S-10’s are used, it appears that there will be a dramatic shift in UCP dollars among States.
If the most recent filed S-10’s are used, it appears that there will be a significant redistribution of UCP dollars among hospital types, with the general theme being a shift from proprietary and non-profit hospitals to government-owned hospitals (in the hundreds of millions of dollars).
MedPAC has repeatedly recommended that S-10 be used to distribute UCP dollars, even in spite of the reported data errors and anomalies – with one MedPAC member stating that, “my experience at CMS was until payment was based on a schedule, the accuracy of that schedule did not tighten up. As soon as payment is made on the schedule, there will be a great degree of attention paid to the accuracy.”
CMS has signaled that it intends to move to using uncompensated care cost from a source like the Medicare cost report worksheet S-10.
What should a hospital be doing today in regards to its reporting of worksheet S-10 data? We continue to stress that hospitals need to consider what may occur in the future and make some important decisions regarding how they will address the issues surrounding the complexity of reporting S-10 data. We further advise that if a hospital chooses to look outside its walls for help that the hospital carefully consider the solution it chooses.
Our comprehensive approach includes a strong data analysis component but also includes a robust “hands-on” component that cannot be accomplished through a software-only solution. Some of the steps required to do a thorough job that cannot be addressed through a software-only solution include:
A comprehensive review of charity care, bad debt and collection policies and procedures
A thorough reconciliation of patient-level detail with financial statements and the Medicare cost report
Testing at the patient-level to ensure policies, procedures and practices are compliant
SCA's comprehensive S-10/UC compliance practice can assist you in navigating the issues surrounding worksheet S-10 data and we are available to discuss what the migration to S-10 may look like for your provider(s). Please contact SCA or visit our website to learn more about our S-10 services.
