For the last few weeks, we have been focusing on the Medicare DSH payment and how the payment calculation changed due to ACA.
Medicare DSH is a process that involves much more than the payment amount found on the cost report for WHAT the hospital should be paid. Now, there are new external factors beyond the calculation that may affect IF the hospital gets paid. The Medicare DSH game is changing and a clear message is being sent that Medicare Disproportionate Share as we know it has changed.
This is evident with the:
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2015 IPPS proposed rule language covering the substantive requirement to claim costs
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Issuance of the PRRB’s Alert 10
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Trends in recent PRRB jurisdictional decisions
While the as-filed cost report has always been the basis by which hospitals claim costs and seek payments, the recent regulatory environment changes have elevated the as-filed cost report thus requiring gold standard attention to the process. Per the 2015 IPPS Proposed Rules, if allowable costs are not properly claimed or non-allowable costs are not properly protested, the hospital may not pass go and likely will not collect its $200 (for those Monopoly fans). While this particular proposed rule was not enacted in the final rules, it does signal the agency’s view regarding how costs should be claimed.
With the number of tripping points growing, now is an important time for hospitals to review their processes for preparing Medicare DSH data reported on the cost report and review whether process revisions are needed to:
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Protect the hospital’s DSH/UC funding
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Remain in compliance with Medicare DSH regulations
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Survive PRRB Alert 10 and the increasing jurisdictional challenges facing hospitals
This includes the need to engage proper legal consultation for protest item and appeal purposes, preparing your data in a way to support the hospital’s compliance with PRRB Alert 10 and continuing to stay up-to-date with PRRB jurisdictional trends.
In the comings weeks, we will be salt and peppering this blog with posts that focus specifically on each of the tripping points mentioned above in more detail. If further information is needed in the meantime, feel free to reach out to us. Tune in for more information on these important topics.