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 27, 2023 regarding a proposed revision to the Skilled Nursing Facility and Skilled Nursing Facility Healthcare Complex Cost Report (proposed Form CMS-2540-23). Links to the Federal Register notice and PRA posting are below and comments must be received by November 27, 2023. Instructions for providing comments are included in the Federal Register notice and a summary of the proposed changes is contained in the Supporting Statement contained within the PRA notice.
Federal Register Notice
Published PRA Notice
CMS issued Transmittal 18 to the 2552-10 on December 29th, 2022. Transmittal 18 has been issued with an effective date of Cost Reporting Periods Beginning on or After October 1, 2022 and implements many of the changes proposed through the PRA process including:
- Addition of Exhibits for reporting:
- Medicare bad debt by beneficiary,
- Medicaid Eligible Day for DSH Eligible Hospitals,
- Charity care charges by patient.
- Total bad debts by patient.
- Identification of permanent adjustments to the TEFRA target amount per discharge.
- Identification of providers purchasing greater than fifty percent of its professional services from an unrelated organization located outside the main hospital’s local area labor market.
- Identification of the number of temporary expansion COVID-19 public health emergency acute care beds.
- Revisions to Worksheet S-10.
- Addition of Worksheet D-6 Parts I through IV to compute allogeneic HSCT acquisition costs as required under §1886(d)(5)(M) of the Social Security Act and in accordance with the statutory requirement under Section 108 of the Further Consolidated Appropriations Act, 2020 (Pub. L. 116-94) for reasonable cost payment.
- Addition of Worksheet E-5 for the contractor to report the outlier reconciliation amount during cost report tentative settlement.
This Transmittal also implements FY 2023 IPPS final rule changes including DGME changes in regards to the Hershey litigation effective for cost reporting periods beginning on or after October 1, 2022. With revisions to Worksheet E-4 and the addition of Worksheet S-2, Part I, Line 68 to identify cost reports for periods beginning prior to October 1, 2022, that are eligible for the modified method of calculating direct GME payments to a teaching hospital when the hospital’s weighted FTE counts exceed their direct GME FTE cap in accordance with the FY 2023 IPPS final rule
Other Worksheet E-4 changes have been made to implement Sections 126, 127 and 131 of the CAA 2021.
This Transmittal also implements changes relating to the Community Health Access and Rural Transformation (CHART) model. The CHART model is effective for discharges ending on or after January 1, 2024, for inpatient services, outpatient services, and CAH swing-bed services.
Other changes include the extension of the low volume adjustment and the Medicare Dependent Hospital (MDH) program, but these changes are subject to subsequent Law provisions.
HFS is evaluating all finalized changes and will be working with CMS to implement and receive approval of the changes within the software.
CMS Published Transmittal 18 at the below link to the CMS website:
https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Transmittals/r18p240i
The Home Office Cost Statement, Form CMS-287-22 Transmittal 1 was published by CMS, on October 28, 2022. Transmittal 1 is effective for cost reporting periods beginning on or after October 1, 2022.
This Transmittal implements an electronic reporting requirement for the home office cost statement and updates the forms to more closely reflect other Medicare form sets. Major changes include:
- Designated Schedule S, Part I as Cost Statement Status and added data elements identifying the status, and added the electronic signature statement to the S, Part II Certification.
- Designated Schedule S-1, Part I as Home Office Data to capture identification information applicable to the home office/chain organization (HO/CO); designated key officer data as Part II. This data was previously reported on Schedule A, Part I.
- Designated Schedule S-2, Parts I, II, and III as Healthcare Components, Non-Healthcare Components, and Region/Division Components, respectively, to list the components of the HO/CO. This data was previously reported on Schedule A, Parts III-V.
- Designated Schedule A as the updated Reclassification and Adjustment of Trial Balance of Expenses. This data was previously reported on Schedule B.
- Designated Schedule A-6 as the updated Reclassifications of Expenses. This data was previously reported on Schedule B-1.
- Designated Schedule A-7, Part I as Analysis of Changes in Capital Asset Balances; designated Part II as Reconciliation of Capital Cost Centers. This data was previously reported on Schedule B-2.
- Designated Schedule A-8 as the updated Adjustments to Expenses. This data was previously reported on Schedule C.
- Designated Schedule A-8-1 Part I as Adjustments Required as a Result of Transactions with Related Organizations and/or Home Office/Chain Organizations; Designated Part II as Interrelationship of Home Office/Chain Organization to Related Organizations. This data was previously reported on Schedule D.
- Designated Schedule B, Parts I, II, & III as Healthcare Components, Non-Healthcare Components, and Region/Division Components, respectively, for direct allocations of capital related costs. This data was previously reported on Schedule E.
- Designated Schedule B-1, Parts I, II, & III as Healthcare Components, Non-Healthcare Components, and Region/Division Components, respectively, for direct allocations of non-capital related costs. This data was previously reported on Schedule E-1.
- Designated Schedule C, Parts I, II, & III as Healthcare Components, Non-Healthcare Components, and Region/Division Components, respectively, for function allocations of capital related costs. This data was previously reported on Schedule F, Part I.
- Designated Schedule C-1, Parts I, II, & III as Healthcare Components, Non-Healthcare Components, and Region/Division Components, respectively, for statistics to functionally allocate capital related costs. This data was previously reported on Schedule F, Part II.
- Designated Schedule D, Parts I, II, & III as Healthcare Components, Non-Healthcare Components, and Region/Division Components, respectively, for function allocations of non-capital related costs. This data was previously reported on Schedule F-1, Part I.
- Designated Schedule D-1, Parts I, II, & III as Healthcare Components, Non-Healthcare Components, and Region/Division Components, respectively, for statistics to functionally allocate non-capital related costs. This data was previously reported on Schedule F-1, Part II.
- Designated Schedule E for the allocation of pooled costs for the double allocation method. This data was previously reported on Schedule G, Part I.
- Designated Schedule E-1, Parts I, II, & III for the allocation of pooled costs to Healthcare Components, Non-Healthcare Components, and Region/Division Components, respectively. This data was previously reported on Schedule G, Part II.
- Added the Schedule F, Parts I, II, and III, to summarize capital related costs by healthcare components, non-healthcare components, and region/division components, respectively.
- Added the Schedule F-1, Parts I, II, and III, to summarize non-capital related costs by healthcare components, non-healthcare components, and region/division components, respectively.
- Designated Schedule G as the updated Balance Sheet. This data was previously reported on Schedule J.
- Designated Schedule G-1 as the updated Statement of Revenues and Expenses. This data was previously reported on Schedule I.
CMS has started the test/approval process and HFS expects T1 software to be approved and available for use soon. The published T-1 transmittal can be found at the link below:
https://www.hfssoft.com/doc/R1P248.zip
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 June 22, 2022 regarding a proposed revision to the Hospital and Health Care Complex Cost Report (proposed Form CMS-2552-10). Links to the Federal Register notice and PRA posting are below and comments must be received by July 22, 2022. Instructions for providing comments are included in the Federal Register notice and a summary of the proposed changes is contained in the Supporting Statement contained within the PRA notice.
Federal Register Notice
Published PRA Notice
CMS issued CR12407 on October 21, 2021 to update the N&AH MA payment rates for 2019 which changed the E-4 reduction amount to 4.07%. The full Change Request is available at: https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Transmittals/r11041otn
We have been informed that CMS updated their COVID-19 Frequently Asked Questions (FAQs) on 1/7/2021 and revised the Cost Reporting Question #1 (on page 105) to grant providers and additional 60 day filing extension “For any cost reporting period not previously identified and ending on a date falling in the period of March 1, 2020 through December 31, 2020”.
| Cost Reporting Period Ending |
Initial Due Date |
Extended Due Date |
Revised Due Date |
| 10/31/2019 |
03/31/2020 |
06/30/2020 |
|
| 11/30/2019 |
04/30/2020 |
06/30/2020 |
|
| 12/31/2019 |
05/31/2020 |
07/31/2020 |
08/31/2020 |
| 01/31/2020 |
06/30/2020 |
08/31/2020 |
|
| 02/29/2020 |
07/31/2020 |
09/30/2020 |
|
| For any cost reporting period not previously identified and ending on a date falling in the period of March 1, 2020 through December 31, 2020, providers are granted an additional 60 days from the initial due date to file their cost reports. |
The current full FAQ listing can be found at the below link:
https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf
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 November 10, 2020 regarding a proposed revision to the Hospital and Health Care Complex Cost Report (proposed Form CMS-2552-10 Transmittal 17). Links to the Federal Register notice and PRA posting are below and comments must be received by January 11, 2021. Instructions for providing comments are included in the Federal Register notice and significant proposed changes include:
- Update to Certification page to better incorporate the electronic signature into the official form.
- Added Worksheet S-12 to collect “Median Payer-Specific Negotiated Charge Data” effective for cost reporting periods ending on or after January 1, 2021
- Added Worksheet D-6 to reimburse for Allogeneic Hematopoietic Stem Cell and CAR T-Cell Therapy effective for cost reporting periods beginning on or after October 1, 2020.
- Added Worksheet E-5 for Outlier Reconciliation at Tentative Settlement for cost reporting periods beginning on or after October 1, 2020.
- Added Exhibit 2A – Replaces Exhibit 2 as of FYB 10/1/2020 with 25 columns and instructions for the information required to support the bad debt claimed in the cost report.
- Added Exhibit 3A – Providing a standard format for the listing of Medicaid Eligible Days for DSH Eligible Hospitals required to support the DSH eligible days reported that must be submitted with cost reports for periods beginning on or after October 1, 2020.
- Added an Exhibit 3B providing a standard format for the information required to support the charity care amounts claimed that must be submitted with cost reports for periods beginning on or after October 1, 2020.
- Added an Exhibit 3C providing a standard format for the information required to support the total bad debt expense claimed.
Federal Register Notice
Published PRA Form
On October 2, 2020 CMS issued Transmittal 1 for the Home Health Agency (HHA) Cost Report, Form CMS‑1728‑20, effective for cost reporting periods beginning on or after January 1, 2020 and ending on or after December 31, 2020. HFS is reviewing the full Transmittal and will be working with CMS to incorporate and receive CMS approval for the revised forms. For cost reporting periods beginning on or after January 1, 2020 and ending on or after December 31, 2020, we will have only one 1728 HFS option going forward. The Compu Max 1728-94 will not be updated to the new 1728-20 and all HFS users will utilize the HFS MCRIF32 1728-20 software.
HFS will be providing a more detailed summary of changes in a future notice and/or WebEx session.
The full Transmittal is available at the CMS website:
https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Transmittals/r1p247
If you have any questions please contact support@hfssoft.com.
The Centers for Medicare & Medicaid Services (CMS) released an additional list of Frequently Asked Questions (FAQs) to Medicare providers regarding the Department of Health & Human Services’ (HHS) Provider Relief Fund and the Small Business Administration’s Paycheck Protection Program payments, also referred to as coronavirus disease 2019 (COVID-19) relief payments. The FAQs provide guidance to providers on how to report provider relief fund payments, uninsured charges reimbursed through the Uninsured Program administered by Health Resources and Services Administration, and Small Business Administration (SBA) Loan Forgiveness amounts. The FAQs also address that provider relief fund payments should not offset expenses on the Medicare Cost Report.
The full FAQ can be found at the below link and the cost reporting questions begin on page 98. Please note that the FAQ did not further extend cost report filing extensions past those published on July 15, 2020.
https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf