HFS News & Information

CMS published new documentation requirements for filing Medicare Cost Report in the Fiscal Year (FY) 2019 Inpatient Prospective Payment System (IPPS) Final Rule.  These new requirements are effective for cost reporting periods beginning on or after October 1, 2018 and additional information can be found in SE 19015 . While CMS initially addressed standardized formats for the submission of the new documentation the following was communicated in the SE 19015.

“As noted in the Final Rule, the Centers for Medicare & Medicaid Services (CMS) agrees that requiring this information to be submitted in standardized formats would ensure consistency of the documentation and facilitate the contractor’s review. CMS plans to include standard formats (templates) in a Paperwork Reduction Act notice to request public comment. Therefore, standardized formats will not be required for cost-report periods beginning on or after October 1, 2018, until further notice. [emphasis added]”

HFS will continue to monitor the implementation of the new documentation requirements and will notify clients of any additional information.

In accordance with the Paperwork Reduction Act (PRA) of 1995, the Centers for Medicare & Medicaid Services (CMS) published a notice in the Federal Register dated September 12, 2019  regarding a proposed revision to the Home Office Cost Statement (proposed Form CMS-287-19).   Links to the Federal Register notice and PRA posting are below and comments must be received by November 12, 2019.  Instructions for providing comments are included in the Federal Register notice and the proposed effective date of the Form CMS-287-19 is effective for the first cost statement period beginning on or after October 1, 2019. Health Financial Systems will be following the progress of the new form set and will develop the 287-19 upon finalization.

Federal Register Notice

Published PRA Form CMS-287-19

CMS published an updated Public Use File (PUF) for the FY 2020 wage index and occupational mix on 1/31/2019. This file reflects the Worksheet S-3, Parts II and III wage data from cost reports for Fiscal Year (FY) 2016 (FY Beginning from 10/1/15 to 9/30/2016). This data has been desk reviewed and verified by the MACs before being published.

The following file has been created and can be downloaded and used with the HFS Wage Index Verification Tool (located under Tools) for the Federal Fiscal Year 2020, January 31, 2017 PUF:

FY_2020_January_31_2019_S3_Data_PUF.csv

CMS published an updated Public Use File (PUF) for the FY 2019 wage index and occupational mix on 2/2/2018. This file reflects the Worksheet S-3, Parts II and III wage data from cost reports for Fiscal Year (FY) 2015 (FY Beginning from 10/1/14 to 9/30/2015). These data will have been desk reviewed and verified by the MACs before being published. The following file has been created and can be downloaded and used with the Wage Index Verification Tool for the Federal Fiscal Year 2019, February 2, 2018 PUF:

FY_2019_February_2_2018_S3_Data_PUF.csv

The Hospital and Hospital Health Care Complex Cost Report, Form CMS-2552-10 was updated to Transmittal 12 by CMS, on November 17, 2017. Transmittal 12 is effective for cost reporting periods ending on or after August 31, 2017.

This transmittal updates Chapter 40, Hospital and Hospital Health Care Complex Cost Report (Form CMS-2552-10), by including subsection (d) Puerto Rico providers as eligible for the electronic health record (EHR) incentive payments and by accommodating the Rural Community Hospital Demonstration Project (§410A Demonstration) adjustment. This transmittal also accommodates the ability for a provider to elect and sign the Certification and Settlement Summary page of the Medicare cost report using an electronic signature pursuant to the FY 2018 IPPS Final Rule.

Changes include:

Worksheet S:
• Added check box to the certification and settlement summary statement for electronic signature submission on cost reporting periods ending on or after December 31, 2017.

Worksheet S-2, Part I:
• Modified instructions for line 39 to reflect the revised eligibility criteria and corresponding low-volume adjustment of 25 percent, effective for discharges occurring on or after October 1, 2017.
• Modified instructions for line 60 for nursing school and allied health education (NAHE) activities to separately identify each individual program reimbursed in accordance with the provisions of 42 CFR 413.85 where reimbursement is made on a reasonable cost basis.
• Added lines 98 through 98.06 related to titles V and XIX reimbursement for critical access hospitals (CAH), reasonable compensation equivalents (RCE), and pass-through costs. These questions were previously addressed by HFS on a non-CMS Worksheet S-2. Part IX.
• Modified line 110 for the Rural Community Hospital Demonstration Project (also known as the §410A Demonstration), as extended by §15003 of the 21st Century Cures Act of 2016, to initiate the calculation of added lines on Worksheet E, Part A, lines 200 through 218, and Worksheet E-2, lines 200 through 215. This calculation was previously addressed by HFS on non-CMS Worksheet E, Part H.
• Added line 111 to identify providers participating in the Frontier Community Health Integration Project (FCHIP) Demonstration.
• Modified questions 167 and 169 to accommodate subsection (d) Puerto Rico providers eligible for the electronic health record (EHR) incentive payment for federal fiscal years 2016 through 2021, in accordance with the CCA 2016, Division O, Title VI, §602.

Worksheet S-3, Part I:
• Added line 33.01 to capture site neutral days and discharges for long term care hospitals (LTCH).

Worksheet A:
• Expanded the instructions for lines 20 and 23 (nursing school and paramedical education) programs to capture the costs of each program on a separate subscript of line 20 and/or line 23, as applicable.
• Added line 77 to capture allogeneic stem cell acquisition costs as defined in CMS Pub. 100-04, chapter 4, §231.11.
• Added line 93.99 to capture the costs of providing hospital-based partial hospitalization program (PHP) services as defined in §1861(ff) of the Act.
Worksheet A-8:
• Added instructions for line 19 to report the nursing school tuition offset adjustment and the allied health/paramedical education tuition offset adjustment. Note that tuition offset adjustments are to be made on Worksheet A-8 and not on Worksheet B-2.
Worksheets B, Part I and B-1:
• Shaded line 116 in columns 19, 21, and 22. This change prevents the allocation of Non-Physician Anesthetists and Interns and Residents costs to the hospital-based Hospice.

Worksheets D, Parts III and IV:
• Modified the worksheets by adding post step-down adjustment columns for nursing school and allied health. Post step-down adjustments were previously accommodated by HFS using non-CMS columns 11-13 on Worksheet D, Part III and non-CMS columns 21-24 on Worksheet D, Part IV
Worksheets E, Part A; E, Part B; E-2, E-3, Parts I through IV; H-4; J-3; M-3; and N-4:
• Added two lines to each reimbursement settlement worksheet to capture demonstration payment adjustments before sequestration, and demonstration payment adjustments after sequestration.

Worksheet E, Part A:
• Added a dedicated line 70.50 to capture the 410A demonstration project payment adjustment.
• Added lines 200 through 218 to calculate the §410A demonstration project payment adjustment amount for inpatient services.

Exhibit 4 (Low-volume adjustment):
• Modified the instructions to calculate the low-volume adjustment payment at 25 percent for services rendered on or after October 1, 2017.
• Shaded line 17.01 (net organ acquisition costs), to eliminate it from the low-volume adjustment payment calculation.

Exhibit 5 (Hospital acquired condition (HAC) adjustment):
• Shaded line 17.01 (net organ acquisition costs), to eliminate it from the HAC adjustment calculation.

Worksheet E, Part B:
• Added line 4.01 to capture the operating outlier reconciliation amount for operating expenses related to outpatient prospective payment (PPS) services.

•Worksheet E-1, Part II:
• Modified the instructions to accommodate the calculation EHR incentive payments for Puerto Rico subsection (d) hospitals in accordance with CAA 2016, Division O, Title VI, §602. This worksheet is not completed by original subsection (d) hospitals for cost reports beginning on or after October 1, 2016.

HFS is currently programming the software changes for transmittal 12 and anticipates approval in the near future. Once approved, HFS will make the update available to users of the software.

The transmittal is available at the CMS website:

https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2017-Transmittals-Items/R12P240.html?DLPage=1&DLEntries=10&DLSort=1&DLSortDir=descending

If you have any questions please contact eric@hfssoft.com.

We have received confirmation from CMS that they have granted an extension from October 31, 2017 until January 2, 2018 for all Inpatient Prospective Payment System (IPPS) hospitals to resubmit certain Worksheet S-10 data. For revisions to be considered, amended FY 2014 and FY 2015 cost reports, due to revised or initial submissions of Worksheet S-10, must be received by Medicare Administrative Contractors (MACs) on or before January 2, 2018. If an IPPS hospital whose FY 2014 or FY 2015 cost report has been final settled requests to revise Worksheet S-10 for that FY 2014 or FY 2015 cost report the request for reopening with the revised data must be received by January 2, 2018.

If you have any questions please contact Support@hfssoft.com.

CMS released a revised final FY 2018 wage index and occupational mix data PUFs on the CMS Web page, August 2, 2017. This file reflects provider correction requests due to CMS or MAC mishandling of the final wage and occupational mix data.

The following file has been created and can be downloaded and used with the Wage Index Verification Tool for the final Federal Fiscal Year 2018 wage index data.

FY_2018_Final_S3_PUF.csv

CMS published the Preliminary Public Use File (PUF) for the FY 2019 wage index and occupational mix on 5/19/2017. This file reflects the Worksheet S-3, Parts II and III wage data from cost reports for Fiscal Year (FY) 2015 (FY Beginning from 10/1/14 to 9/30/2015). Hospitals will have until September 1, 2017 to request revisions to the wage data posted in the May PUF. The following file has been created and can be downloaded and used with the Wage Index Verification Tool for the Federal Fiscal Year 2019,

Click here to download the Preliminary PUF: FY_2019_Preliminary_S3_PUF_HFS_Modified.csv

CMS published the Final FY 2018 wage index and occupational mix data PUFs on their Web page. Hospitals will have until May 30, 2017 to verify their data and submit correction requests to both CMS and their MAC to correct errors due to CMS or MAC mishandling of the final wage and occupational mix data.

Changes to data will be limited to situations involving errors by CMS or the MAC that the hospital could not have known about before review of the final April PUFs. CMS and the MACs must receive all requests by this date via mail and email to the addresses above. NOTE: CMS emphasizes that data that were incorrect in the preliminary or January wage index data PUFs, but for which no correction request was received by the February 17, 2017, deadline, will not be changed at this stage for inclusion in the wage index. Each correction request must include all information and supporting documentation needed for CMS and the MAC to determine whether or not the hospital’s request meets the criteria for a correction to their data at this point in the wage index development. The MACs and DAC will review each request upon receipt and consult to determine whether or not the request qualifies for correction of the final wage or occupational mix data.

The following file has been created and can be downloaded and used with the Wage Index Verification Tool for the Final Federal Fiscal Year 2018, April 28, 2017 PUF:

FY 2018 April 18, 2017 Wage Index PUF HFS CSV 2552-10

The Independent Rural Health Clinic (RHC)/Freestanding Federally Qualified Health Centers (FQHC) Cost Report, Form CMS-222-92 was updated to Transmittal 13 by CMS, on February 17, 2017. Transmittal 13 is effective for cost reporting periods ending on or after September 30, 2016.

Effective for cost reporting periods beginning on or after October 1, 2014 the Form CMS-222-92 cost report is only applicable to RHC providers. FQHC providers are currently required to file the Form CMS-224-14 cost report.

Changes include:

• On Worksheet A, expanded the instructions for Allowable and Non-Allowable GME Pass through Costs on lines 20.50 and 53.50, respectively.
• Also on Worksheet A, added the following cost centers:
  • Line 55.50 for Chronic Care Management (CCM)
  • Line 55.60 for Telehealth
• Worksheet A-2, line 8.01 was added to accommodate the application of the RCE adjustment for teaching physicians.
• Worksheet B, Part II, line 14.01 was revised to eliminate the separate calculation of overhead for direct graduate medical education (GME).
• Revised Worksheet C, Part II, line 15.10 for direct GME costs.
• Also on Worksheet C, Part II, added line 20.99 to capture the Pioneer Accountable Care Organization (ACO) demonstration payment adjustment amount in accordance with ACA 2010, §3022.

HFS is currently programming the software changes for transmittal 13 and anticipates approval in the near future. Once approved, HFS will make the update available to users of the software.

The transmittal is available at the CMS website:

https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2017-Transmittals-Items/R13P299.html?DLPage=1&DLEntries=10&DLSort=1&DLSortDir=descending

If you have any questions please contact eric@hfssoft.com.