Southwest Consulting Associates Blog

FY 2020 Inpatient Skilled Nursing (SNF) Proposed Rule Update

Posted by Stacie Snider on Apr 26, 2019 11:25:38 AM

The FY 2020 Inpatient Skilled Nursing Facility Proposed Rule was put on display for public inspection on April 19, 2019. The proposed rule is scheduled to be published in the Federal Register April 25, 2019, however, the pre-publication can be viewed here. If finalized, this SNF rule will affect discharges on or after October 1, 2019.

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Topics: Industry Updates, regulations, proposed rule, provider reimbursement, inpatient SNF

FY 2020 IPPS Proposed Rule

Posted by Jamie Pennington on Apr 24, 2019 3:23:43 PM

The FY 2020 Inpatient Prospective Payment System (IPPS) Proposed Rule was put on display for public inspection on April 23, 2019, and is scheduled to be published in the Federal Register on May 3, 2019.  The pre-publication version can be viewed HERE or on the FY 2020 IPPS Proposed Rule homepage.  If finalized, these changes will go into effect October 1, 2019.  All public comments to the proposed rule are to be received by 5 pm EST on Monday, June 24, 2019.

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Topics: Medicare DSH Reimbursement, Industry Updates, S-10, regulations, proposed rule, worksheet s-10, factor 3, uncompensated care payment, ipps rule, provider reimbursement

FY 2020 Inpatient Psych Proposed Rule Update

Posted by Stacie Snider on Apr 23, 2019 3:51:59 PM

The FY 2020 Inpatient Psych Proposed Rule was put on display for public inspection on April 17, 2019. The proposed rule is scheduled to be published in the Federal Register April 23, 2019. The pre-publication can be viewed here. When finalized, this IPF rule will affect discharges on or after October 1, 2019.

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Topics: regulations, proposed rule, inpatient psych

FY19 IPPS Final Rule: Cost Report Worksheet S-10 Is Here To Stay

Posted by Kyle Pennington on Oct 12, 2018 1:32:37 PM

The Fall 2018 issue of HFMA New Jersey's Garden State FOCUS magazine included an article titled, "FY 2019 IPPS Final Rule Update: Worksheet S-10 Is Here To Stay" which takes a look at:

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Topics: Medicare DSH Reimbursement, S-10, regulations, final rule, worksheet s-10

2019 IPPS Proposed Rule: Cost Report Worksheet S-10 to determine Two-Thirds of Factor 3 for Uncompensated Care Payment

Posted by Jamie Pennington on Apr 25, 2018 3:59:40 PM

The 2019 IPPS Proposed Rule will be published in the Federal Register on May 7, 2018. If finalized, these changes will go into effect October 1, 2018. The pre-published version can be viewed HERE. Public comments will be accepted until 5 p.m. EDT on June 25, 2018.  Below is SCA’s "as brief as we could make it", yet comprehensive summary on the Medicare DSH/Uncompensated Care payment portion (pages 818-877) of the proposed rule as it will affect qualifying DSH hospitals.

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Topics: DSH Reimbursement, Medicare DSH Reimbursement, uncompensated care, Compliance, Industry Updates, S-10, regulations, proposed rule, healthcare finance, worksheet s-10

Robust Factor 3 Comments Not Enough to Sway CMS & 2018 IPPS Final Rule

Posted by Michael Newell on Sep 5, 2017 12:53:25 PM

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:

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Topics: DSH Reimbursement, Medicare DSH Reimbursement, S-10, regulations, final rule, worksheet s-10, factor 3

2018 IPPS Final Rule: Worksheet S-10 Comes Off the Bench

Posted by Jamie Pennington on Aug 22, 2017 9:49:09 AM

The 2018 IPPS Final Rule was published in the Federal Register on August 14, 2017. The finalized changes will go into effect October 1, 2017. The Federal Register version can be viewed HERE (Medicare DSH begins on page 38189).  Below is SCA’s brief, yet comprehensive summary on the Medicare DSH/Uncompensated Care payment portion of the final rule as it will affect DSH hospitals.

 

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Topics: DSH Reimbursement, Medicare DSH Reimbursement, uncompensated care, Compliance, Industry Updates, S-10, regulations, final rule, worksheet s-10

2018 IPPS Proposed Rule: Recommendations in Advance of Final Rule

Posted by Jeff Norman on Jul 31, 2017 4:10:58 PM

The FY 2018 IPPS proposed rule was published April 28, 2017. Public comments have been submitted and we are awaiting the final rule.  For reference, the 2017 IPPS final rule was posted the first week in August 2016 so we are on the cusp on the 2018 final rule.  

 

In our last proposed rule post, while we stated that there was a brief moment of deja vu with regards to using Worksheet S-10 to distribute the uncompensated care payment to qualifying Medicare DSH hospitals for FY 2018, we also stated that based on the language used in the proposed rule, we believe that the change will stick this time.  Despite challenges on the accuracy of Worksheet S-10 data, CMS goes out of their way to lay out the reasoning for using S-10 now.  And, with the issuance of Transmittal 1863 and the notice about FY 2014 S-10 revisions, our case may be even stronger now.   From experience, we all know that anything can happen but we think Medicare DSH hospitals should take notice (and quickly) with this proposed rule, subsequent Transmittal and Notice and prepare themselves as best they can to deal with this significant change. Here’s what we recommend hospital’s be working on in advance of the final rule, in order of priority.

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Topics: DSH Reimbursement, Medicare DSH Reimbursement, S-10, regulations, final rule, proposed rule, worksheet s-10, CMS transmittal

IPPS Proposed Rule 2018: Factor 3 - CMS Digging Heels In

Posted by Michael Newell on Jun 22, 2017 1:10:34 PM

On April 28, 2017, CMS published the FFY 2018 IPPS Proposed Rule in the Federal Register.  Go HERE for our summary of the Medicare DSH/Uncompensated care payment portion of the rule.  After years of discussion to use Worksheet S-10 uncompensated care data to distribute the Medicare DSH/UC pool always ending with CMS “kicking the can down the road”, it appears that CMS has finally dug their heels in.  Who else just had a moment of deja vu?  

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Topics: DSH Reimbursement, Medicare DSH Reimbursement, uncompensated care, S-10, regulations, proposed rule, worksheet s-10, factor 3

2018 IPPS Proposed Rule: Factor 3

Posted by Jeff Norman on Jun 20, 2017 3:07:15 PM

On April 28, 2017, CMS published the FFY 2018 IPPS Proposed Rule in the Federal Register.  Go HERE for our summary of the Medicare DSH/Uncompensated care payment portion of the proposed rule.  After years of discussion on Worksheet S-10 and false starts on the use of uncompensated care data for Medicare DSH/UC pool distribution purposes, CMS appears to finally be moving forward with implementation.  Did anyone else have a moment of deja vu?  

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Topics: DSH Reimbursement, Medicare DSH Reimbursement, uncompensated care, S-10, regulations, proposed rule, worksheet s-10, factor 3

About This Blog

The climate of provider reimbursement is ever-changing and this blog is intended to keep you up-to-date on the latest information regarding:

  • DSH Reimbursement
  • 340B Pharmacy Drug Discount Program
  • Compliance Issues
  • Litigation Surrounding Provider Reimbursement

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