Southwest Consulting Associates Blog

The 2019 IPPS Proposed Rule was put on display for public inspection on April 24, 2018 and is scheduled to be published in the Federal Register on Monday, May 7, 2018.  The pre-publication version can be viewed HERE.  All public comments to the proposed rule are to be received by 5 p.m. EST on Monday, June 25, 2018.  

In regards to the Medicare DSH/UC payment, Worksheet S-10 will be used to calculated two-thirds of a qualifying provider's Factor 3.  SCA will be reviewing and analyzing the full details of the proposed rule and its components, and we will provide our conclusions in the coming week. 

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?

CMS just posted the FFY 2016 SSI ratios to their website.  The FFY 2016 SSI ratio file (DSH Adjustment and 2015-2016 File [ZIP, 248KB]) can be found in the Downloads section of CMS' Disproportionate Share Hospital (DSH) webpage or by following the link below:

The Centers for Medicare and Medicaid Services (CMS) has posted a Questions and Answers document providing clarification related to Medicare Cost Report Worksheet S-10.  If you’ll recall, CMS issued Transmittal 11 in September 2017 that made a number of revisions to the instructions for reporting data on cost report Worksheet S-10.

It is fitting that the month of Thanksgiving also begins the 4th year of SCA's healthcare blog. We thank you, the readers, for being a part of our story as we share the latest in Medicare DSH reimbursement, Worksheet S-10 uncompensated care and 340B drug pricing program news. You trust us with your time, and we appreciate being a source of insight in this ever-changing industry. As we celebrate our 3rd anniversary and start to our 4th year, let's take a look at how far we have come, together.

On October 20, 2017, CMS issued another Technical Direction Letter (TDL) extending the deadline for all IPPS hospitals to submit revised or initial FFY 2014 and 2015 Worksheet S-10’s to January 2, 2018.  Southwest Consulting Associates confirmed this directly with CMS' Division of Acute Care and is monitoring the CMS website for a posted notice, which CMS also stated would be available shortly.  Until the official notice is posted, please contact your MAC for additional information.

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:

As a result of Hurricanes Harvey, Irma and Maria, CMS posted a notice on its website last month 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 revised Worksheet S-10's.  CMS subsequently issued a Technical Direction Letter (TDL) extending the same 31-day extension to file updated FFY 2014 and 2015 Worksheet S-10’s to October 31, 2017 for ALL IPPS providers.  

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.

As we all now know, CMS proposed transitioning to the use of uncompensated care cost per worksheet S-10 in the IPPS 2017 rulemaking cycle. For many reasons that we have discussed in the past and that CMS reiterated in the last rulemaking cycle, that plan was not finalized. And although many people were left thinking that CMS was going to make some reforms to the definitions and reporting processes before going forward, they did leave the door open just a bit last year with regarding to moving forward with the change to S-10 in FY 2018. As we now know, they chose to squeeze through that opening and have finalized plans to begin the transition to using worksheet S-10 beginning in FY 2018. As overall justification, CMS stated: