In discussions that we have had externally, there seems to be confusion around which cost reporting periods are applicable to a specific Federal Fiscal year (FFY). The FFY begins 10/01 and ends 09/30, so if your hospital's FYE is not 9/30, how do you know which of your cost reports falls into a specific FFY?
If you remember, in the FY 2018 IPPS Final Rule published in August of 2017, CMS finalized the inclusion of uncompensated care data from Medicare cost report Worksheet S-10 to calculate qualifying providers’ Factor 3. A provider's Factor 3 calculation is computed based upon data from three FFY cost reporting periods as defined by CMS that contain a blend of low-income days and UC costs per worksheet S-10. So, in anticipation of the FY 2019 IPPS proposed rule which could be posted any day/minute now, we'll focus on the Factor 3 components for FFY 2019 and which hospital cost reporting periods should be applicable.
FFY 2019 IPPS Proposed Rule Factor 3:
FFY 2013 Medicaid Days + FFY 2016 SSI days
FFY 2014 Uncompensated care cost per S-10
FFY 2015 Uncompensated care cost per S-10
FFY 2013 does not necessarily mean your hospital's fiscal year end 2013 cost report. Remember, the FFY runs from 10/01 and ends 09/30, that means FFY 2013 runs from 10/1/12 through 9/30/13. Hospital cost reports beginning during this time period (10/1/12-9/30/13) will be used for the FFY 2013 portion of the Factor 3 calculation.
Let's say your hospital FYE is 6/30. Here's what cost reports should be used for your Factor 3 for FFY 2019:
6/30 Hospital Fiscal Year End:
6/30/14 Medicaid Days + 9/30/16 SSI days
6/30/15 Uncompensated care cost per S-10
6/30/16 Uncompensated care cost per S-10
Let's do one more example:
12/31 Hospital Fiscal Year End:
12/31/13 Medicaid Days + 9/30/16 SSI days
12/31/14 Uncompensated care cost per S-10
12/31/15 Uncompensated care cost per S-10
Click the image above for a table with FFY's and general hospital cost reporting period start dates that we think may be a helpful reference for you as we gear up for another year of rule-making. Wherever your hospital cost report start date falls in the FFY column, that is the FFY year your cost report coincides with.
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