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
On Thursday, July 13, 2017, CMS announced that “amended FY 2014 cost reports due to revised or initial submissions of Worksheet S-10 received by Medicare Administrative Contractors on or before September 30, 2017, will be uploaded to the Healthcare Cost Report Information System by December 2017”. In its announcement, CMS stated that “hospitals have requested CMS provide them with an additional opportunity to revise the Worksheet S-10 submitted with their FY 2014 cost reports (starting on or after October 1, 2013, and prior to October 1, 2014)”.
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Topics:
DSH Reimbursement,
Medicare DSH Reimbursement,
Industry Updates,
S-10,
worksheet s-10,
factor 3,
CMS transmittal
On Friday, June 30, 2017, CMS released Transmittal 1863 (beginning on page 2), which included, among other items, guidance for MACs to follow for accepting cost reports containing revised Worksheet S-10 information. Similar to last year's Transmittal 1681, in order for MACs to accept amended cost reports due to revisions to Worksheet S-10 for FY 2015, CMS has put providers on notice by stating that “hospitals must submit their amended cost report containing the revised Worksheet S-10…no later than September 30, 2017.” CMS added, “Submissions received on or after October 1, 2017 will not be accepted.”
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Topics:
DSH Reimbursement,
Medicare DSH Reimbursement,
Industry Updates,
S-10,
worksheet s-10,
factor 3,
CMS transmittal
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
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?
Read More
Topics:
DSH Reimbursement,
Medicare DSH Reimbursement,
uncompensated care,
S-10,
regulations,
proposed rule,
worksheet s-10,
factor 3
The FY 2018 IPPS proposed rule was published in the Federal Register on April 28, 2017. All comments to the rule were to be submitted to CMS by Tuesday, June 13, 2017. Like in past years, Southwest Consulting Associates (SCA) performed extensive analysis of the proposed rule and submitted comments in response to CMS’ FY 2018 IPPS Notice of Proposed Rulemaking (NPRM). SCA’s comments primarily related to the proposed changes in the payment adjustment for Medicare Disproportionate Share Hospitals (DSH) including the Uncompensated Care (UC) payment component.
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Topics:
DSH Reimbursement,
Medicare DSH Reimbursement,
uncompensated care,
Industry Updates,
S-10,
regulations,
proposed rule,
worksheet s-10
On April 28, 2017, CMS published the FFY 2018 IPPS Proposed Rule in the Federal Register. 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 have finally moved forward with implementation. Go HERE for our summary of the Medicare DSH/Uncompensated care payment portion of the proposed rule. In this post, we will take a dive into Factor 2 as described in the proposed rule. For a quick refresher on Factor 2, go HERE.
Read More
Topics:
DSH Reimbursement,
Medicare DSH Reimbursement,
uncompensated care,
S-10,
regulations,
proposed rule,
worksheet s-10,
factor 2
On April 28, 2017, CMS published the FFY 2018 IPPS Proposed Rule in the Federal Register. 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 have finally moved forward with implementation. Go HERE for our high-level summary of the Medicare DSH/Uncompensated care payment portion of the proposed rule. In this post, we will take a dive into Factor 1 as described in the proposed rule. For a quick refresher on Factor 1, go HERE.
Read More
Topics:
DSH Reimbursement,
Medicare DSH Reimbursement,
uncompensated care,
S-10,
regulations,
proposed rule,
worksheet s-10
The 2018 IPPS Proposed Rule was published in the Federal Register on April 28, 2017. If finalized, these changes will go into effect October 1, 2017. The published version can be viewed HERE. Public comments will be accepted until 5 p.m. EDT on June 13, 2017. Below is SCA’s brief, yet comprehensive summary on the Medicare DSH/Uncompensated Care payment portion of the proposed 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,
proposed rule,
healthcare finance,
worksheet s-10
