HFS News & Information

On August 21, 2020 CMS posted two significant change requests to its website.

CR 11644 – Communicated changes to the cost report acceptability checklists used by MACs to make acceptable cost report determinations.  This CR removes the review of the PI file encryption codes and establishes Provider documentation variance allowance of +-3 percent.  The full Change Request is available at: https://www.cms.gov/files/document/r10316otn.pdf.

In addition, CMS issued CR 11642.  This CR provides MAC instructions regarding the calculation of nursing and allied health Medicare+Choice payments and the proportional reduction to MA direct GME payments.  The changes to the proportional reduction to MA direct GME payments were initiated in Transmittal 16 of Form CMS 2552-10.  The full Change Request is available at: https://www.cms.gov/files/document/r10315otn.pdf.

The Hospital Complex, 2552-10 was updated to Transmittal 16 by CMS, on April 30, 2020. Transmittal 16 is effective for cost reporting periods ending on or after December 31, 2019.

The primary purpose of Transmittal 16 was to incorporate cost reporting changes for the Pennsylvania Rural Health Model (PARHM) demonstration.  Other major changes include:

• Modification of Worksheet E-4 to accommodate DGME reimbursement for CAHs that train residents in excluded IPF or IRF units.
• Modification to the calculation of the percentage reduction of the MA direct GME payments for the calculation of the MA nursing and allied health (NAHE) payment adjustments.  The reductions will be changed on an annual basis using the below factors, previously the reduction factor was 14.13%

As this Transmittal is effective for cost reporting periods ending on or after December 31, 2019, it does not incorporate any changes relating to COVID-19 pandemic cost reporting changes.

CMS has not yet started the test/approval process, however, HFS expects T16 software to be approved and available for use in June.  Preparation can continue on the current T15 software and will be compatible with the T16 update when made.  CMS is encouraging providers to wait for T16 software availability to submit their MCR’s. The published T-16 transmittal can be found on CMS’ website at the link below:

https://www.cms.gov/regulations-and-guidanceguidancetransmittals2020-transmittals/r16p240

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

The Centers for Medicare & Medicaid Services (CMS) released the final FY 2020 wage index data public use files (PUFs) on APRIL 30, 2019.  The files are available for the limited purpose of identifying any potential data entry or transmission errors made by CMS or the A/B Medicare Administrative Contractors (MACs), NOT for the initiation of new revision requests.   Hospitals should promptly review their final wage index data files and compare that to the data in the April 30, 2019 PUF to ensure that their Worksheet S-3 wage are accurate.  All requests from hospitals for corrections to their FY 2020 wage index data files must be submitted to and received (i.e., not postmarked) by both the A/B MACs and CMS on or before May 30, 2019.

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, April 30, 2019 PUF:

FY_2020_April 30 2019_S3_Data_PUF.csv

CMS published the Proposed Rule Public Use File (PUF) for the FY 2019 wage index and occupational mix on 4/27/2017. 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). As noted in the wage index development timetable hospitals have the right to request corrections to their wage index data files if they can establish that the A/B MACS or CMS made a data entry or transmission error in the final FY 2019 wage index data files. A hospital requesting a correction must submit its request, by hard copy and email, along with complete, appropriate detailed documentation, to both its A/B MACS and CMS, no later than May 30, 2018.

The following file has been created and can be downloaded and used with the Wage Index Verification Tool for the Federal Fiscal Year 2019, Preliminary PUF:

FY_2019_April_27_2018_S3_Data_PUF.csv

Electronic signature of the Certification and Settlement Summary page of the Medicare cost reports

The Final Rule for the Fiscal Year 2018 update to the Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals was published in the August 14, 2017 Federal Register. The Final Rule included a provision for the electronic signature of the Certification and Settlement Summary page of the Medicare cost report. This provision is available as an option for cost reporting periods ending on or after 12/31/2017 in accordance with 42 CFR 413.24(f)(4)(iv).

HFS has been updating MCR system as CMS has released the transmittals to allow our users to electronically sign their MCR’s.   Users have several options on how to sign based on the flexibility built into the IPPS Final Rule and HFS has deigned options to maximize convenience. If the HFS user preparing the report has authority to sign the report, they can do so within the system. If the preparer is not the authorized signer they can specify the e-mail address of the authorized person and HFS, using our SaFE site, will facilitate the process of presenting the package to the authorized person and collecting the electronic signature. Signing can be accomplished on any device that has access to e-mail – yes, we have tested on our phones! For documentation and videos, please visit our website https://www.hfssoft.com/webinars/tutorials.

CMS Transmittals Issued include the following:

• Hospital 2552-10 – Implemented in T-13 for further information click here
• Skilled Nursing Facility 2540-10– Implemented in T-8 for further information click here
• Organ Procurement Organization 216-94– Implemented in T-7 for further information click here
• Home Health Agency 1728-94– Implemented in T-18 for further information click here
• ESRD 265-11– Implemented in T-4 for further information click here

In addition CMS is currently reviewing the HFS software for the following transmittals and we anticipate approvals shortly:

• FQHC 224-14 Transmittal 2
• Hospice 1984-14 Transmittal 3

Transmittals for the RHC 222-92 and CMHC 2088-92 have not yet been issued by CMS.

Option to electronically transmit their MCR through the Medicare Cost Report e-Filing (MCReF) system

While separate from the electronic signature of the Certification and Settlement Summary page of the Medicare cost report. CMS has announced a new option for the submission of Medicare Cost Reports. The new Medicare Cost Report e-Filing System or MCReF is not yet publicly availability but CMS has scheduled a training webcast to provide instruction for use of the new system. More information on the May 1, 2018 training webcast can be found at:

https://www.cms.gov/Outreach-and-Education/Outreach/NPC/National-Provider-Calls-and-Events-Items/2018-05-01-Cost-Reporting.html

CMS presented an overview of the MCReF system to MCR vendors on 4/10/2018. The portal is nice and we think the provider community will find it convenient. The portal is designed to collect files for MCR submissions. This includes the EC (SN, HH, CM, HS, RF, OP, RD, FQ) PI, signed certification page, IRIS files if appropriate and other files that you would normally send to your MAC (Maybe .MCRX and .MCP files).

We encourage users to attend the CMS webcast. We will be in attendance and will continue to learn more about this process and make sure that we are doing everything we can to be compatible and supportive of the new process. Let us know if you have any questions and we will do our best to get answers.

If you have any questions, please contact Eric Swanson at eric@hfssoft.com.

Previously CMS issued Transmittal 12 to The Hospital and Hospital Health Care Complex Cost Report, Form CMS-2552-10. HFS provided a detailed overview of the T-12 and links to the CMS website at:

CMS issues Transmittal 12 to the Provider Cost Reporting Forms and Instructions, Chapter 40, Form CMS-2552-10

HFS has been notified that CMS is in the process of issuing a Transmittal 13 for the hospital cost report, Form CMS-2552-10. The T-13 will reissue all content from T-12 and revises the effective date from cost reporting periods ending on or after August 31, 2017, to cost reporting periods ending on or after September 30, 2017. CMS anticipates T-13 will be issued by the end of this week.

We have also been notified that any hospital with a fiscal year ending on or after September 30, 2017, must submit using T-13. However, if a hospital with a fiscal year ending on or after September 30, 2017, has already submitted their cost report using T-11, it is not required to resubmit the cost report unless that provider is participating in the Rural Health Demonstration Project and/or has Nursing and Allied Health Education (NAHE) programs. All fiscal year ending September 30, 2017, cost reports will be final settled on the latest transmittal.

Additional HFS Note: There are two major revisions impacting Hospital with NAHE programs and hospitals reimbursed under the Rural Health Demonstration Project.

NAHE – T-12 modified instructions for Worksheet S-2, Part I, 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. Details for each NAHE program will be reported on subscripts on line 60 and separate cost centers must be identified on Worksheet A for each program.

Rural Health Demonstration Program – CMS has added Worksheet E, Part A, lines 200 through 218 to calculate the §410A demonstration project payment adjustment amount for inpatient services. HFS previously accommodated this provision on HFS Worksheet E, Part H.

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

CMS issued Form 2552-10, Transmittal 11, on September 29, 2017. This transmittal clarifies the definitions and instructions for uncompensated care, non-Medicare bad debt, non-reimbursed Medicare bad debt, and charity care to include uninsured discounts, as well as modifies the calculation relative to uncompensated care costs.

Revisions include:
• Worksheet S-10:
• Revised the instructions for line 20 for subsection (d) Puerto Rico hospitals, charity care and uninsured discounts.
• Modified the calculation and clarified the instructions on line 21, column 2, for insured patients and non-covered charges for insured patients for days exceeding a length-of-stay limit.
• Clarified the instructions for line 22.
• Clarified that the amount reported on line 26 is net of recoveries.
• Added line 27.01 to capture Medicare allowable bad debt for the entire facility.
• Modified the instructions for line 28 to only capture the non-Medicare bad debt expense.
• Modified the calculation for line 29.

The full transmittal can be found at the CMS Website at:
https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2017-Transmittals-Items/R11p240.html?DLPage=1&DLEntries=10&DLSort=1&DLSortDir=descending

In addition a Medlearn Matters article SE17031 to communicate the extension from September 30, 2017 until October 31, 2017 for ALL Inpatient Prospective Payment System (IPPS) hospitals to resubmit certain Worksheet S-10 data. This article is also intended to provide additional guidance to 1886(d) hospitals by summarizing revisions and clarifications to the instructions for the Worksheet S-10 of the Medicare cost report.

The full article can be found at: https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/SE17031.pdf

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

CMS has granted an extension from September 30, 2017 until October 31, 2017 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 October 31, 2017.

HFS anticipates the CMS official publication of this extension and additional clarification regarding S-10 changes, no later than Friday September 29th and will notify clients when available.

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