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
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For FFY 2018, CMS again proposed to begin utilizing uncompensated care data from Worksheet S-10 to calculate qualifying providers’ Factor 3.
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As you’ll recall, the proposed calculation used a combination of Medicaid/SSI days and one year of Worksheet S-10 data to calculate providers' average Factor 3 for FFY 2018.
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Instructed MACs to accept amended cost reports due to revisions to Worksheet S-10 for FY 2015, and CMS 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.”
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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”.
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CMS finalized use of uncompensated care data from Worksheet S-10 to calculate qualifying providers’ Factor 3 beginning in FFY 2018.
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CMS further stated that while “cost reports beginning in FY 2017 will be the first cost reports for which Worksheet S-10 data will be subject to desk review, we expect cost reports beginning in FY 2014, FY 2015, and FY 2016 to be subject to further scrutiny after submission.”
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CMS initially issued an extension to file S-10 for those states affected by hurricanes until October 31, 2017.
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Two weeks later, CMS issued a TDL granting the extension for ALL states.
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Transmittal 11 made a number of revisions to the instructions for reporting data on cost report Worksheet S-10. These revised instructions should have been incorporated by hospitals into the FFY 2014 & 2015 Worksheet S-10 revisions and submitted by the applicable deadlines.
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In its Technical Direction Letter, CMS extended the deadline for all IPPS hospitals to submit revised or initial FFY 2014 & 2015 Worksheet S-10’s by January 2, 2018.
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Clarified the deadlines for uploading revised or initial submissions of FY 2014 and FY 2015 cost report Worksheet S-10.
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CMS also provided clarification for hospitals requesting Worksheet S-10 revisions where their FY 2014 and FY 2015 cost reports had already been final settled.
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CMS stated that if a hospital “requests to revise Worksheet S-10 for that FY 2014 or FY 2015 cost report and that request was received on or before December 1, 2017, MACs shall issue a Notice of Reopening (NOR), issue a revised notice of program reimbursement (RNPR), and upload the FY 2014 or FY 2015 revised cost report to the Health Care Provider Cost Report Information System, otherwise known as HCRIS, on or before December 31, 2017.”
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If the hospital’s request is “received between December 2, 2017 and January 2, 2018 (inclusive of those dates),” the MACs are instructed to follow the same processes “and upload the FY 2014 or FY 2015 revised cost report to HCRIS on or before January 31, 2018.”
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Provided clarification related to Medicare Cost Report Worksheet S-10.
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The Q&A posted provides 20 examples related specifically to Worksheet S-10 for hospital providers to consider. If you haven’t yet had an opportunity to read the Q&A, we’d recommend it.
As you can see, a lot has happened in a short time related to S-10. And, 2018 could be very similar as there seems to still be significant "confusion" surrounding the Worksheet S-10 uncompensated care cost reporting instructions resulting from the issuance of Transmittal 11 and the subsequent Q&A posted on the CMS website. In addition, FFY 2017 cost reports are subject to desk review and CMS is also on record indicating that FFYs 2014-2016 may also be subject to further scrutiny upon submission. MACs are likely developing their audit protocols and will also need to interpret CMS' instructions. The hospital provider community awaits to see if CMS will address any outstanding issues in the FFY 2019 IPPS proposed rule due out this Spring.
Be sure to subscribe to our blog because in the coming weeks, we will be featuring:
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Common hospital pain points & what we learned as a result of 216 Worksheet S-10 client engagements (and counting),
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Best practices for completing Worksheet S-10,
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S-10 from an audit perspective, &
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Next step recommendations for your FFY 2016 & 2017 Worksheet S-10 submissions.
