Southwest Consulting Associates Blog

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:

The 2019 IPPS Final Rule was put on display for public inspection on August 2, 2018 and is scheduled to be published in the Federal Register on Monday, August 17, 2018.  The pre-publication version can be viewed HERE (Medicare DSH begins on page 969).  SCA will be reviewing and analyzing the details of the final rule and its components and we will provide more detailed conclusions soon.

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.

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. 

It was an eventful 2017 for CMS when it came to Worksheet S-10 and while we blogged on each milestone individually, we thought a resource summarizing EVERYTHING that took place last year regarding S-10 would be helpful for reference.  So let's waste no time and review the S-10 2017 "appearances" starting with how Medicare cost report Worksheet S-10 rose to fame.

April 28, 2017 - CMS posts the FFY 2018 IPPS Proposed Rule

• For FFY 2018, CMS again proposed to begin utilizing uncompensated care data from Worksheet S-10 to calculate qualifying providers’ Factor 3.

On January 23, 2015, Michael Newell, SCA’s President, authored a blog article entitled 340B meets S-10, which can be found HERE.  The impetus for this article was a report published by the Alliance for Integrity and Reform of 340B (AIR340B).  In this article, the authors concluded that 340B hospitals appear to provide only a minimal amount of charity care thus calling into question whether or not Congress’ intentions for the 340B program are being met. The data used to reach this conclusion was derived from the Medicare Cost Report, CMS-2552-10, S-10 – the very data that CMS currently uses as the basis to allocate the uncompensated care pool for the Medicare DSH/uncompensated care program. 

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.