HFS News & Information

CMS recently issued a new Transmittal 17 for the SNF, 2540-96. T.17 is effective for FY End 10/1/2009 and after (i.e. must use T.17, our version 17). W/S S-2 line 20 was revised to REQUIRE an answer, F for a Full report; L for a Low Medicare Utilization report; and N for a No Medicare Utilization report. W/S S-5, lines 10 and 11 are now N/A, effective for FYE 5/31/2009 and after, due to HIPPA data sensitivity. W/S S-4 part III, columns 5 and 6 (SCIC visits), is N/A effective for services on or after 1/1/2006. Similarly, W/S H-6, lines 8.05, 8.06, 8.09, and 8.10, are N/A for SCIC payments. W/S I-4 was revised for the H1N1 vaccine changes. Effective for services on or after 9/1/2009, new columns 2.01 and 2.02 were added for H1N1 Only, and Influenza and H1N1 combined, respectively. W/S E part III, line 10.04 is a NEW line added for Dual Eligible Bad debt Recoveries.

CMS issued a new Transmittal 14 for the HHA (1728-94 Forms). It is effective for FYE on or after 10/1/2009 (i.e. must use T.14 for these FYE). T.14 implements the RHC/FQHC phase out of the Outpatient Mental Health Limit of 62.5%, over 5 years. W/S RF-3, line 14 calculation will remain 62.5% for services through 12/31/2009. For services 1/1/2010 to 12/31/2011, the Limit is 68.75%. For services 1/1/2012 to 12/31/2012, the Limit is 75%. For services 1/1/2013 to 12/31/2013, the Limit is 81.25%. For services on or after 1/1/2014, the Limit is zero, or 100% reimbursement is computed.

T.14 also implements the H1N1 vaccine changes, effective for services on or after 9/1/2009. W/S RF-4 has added columns 2.01 and 2.02 to capture data and calculate the costs of H1N1 and Influenza vaccines. Medical Supply cost, Total Injections, and Medicare Injections must be split (identified) between Pneumococcal, Seasonal Influenza, H1N1 Only, and Influenza and H1N1 combined.

T.14 codified the change to eliminate W/S S-3 part IV, columns 5 and 6, for SCIC. These columns are no longer used effective for services on or after 1/1/2008. T.14 also added the FI/MAC “name” to S-2 line 29.02, column 3. We have a table in our W/S S-2 HELP, with all the names. We are awaiting the CMS Test Case and beginning of the approval process for T.14.

Transmittal 21 is effective for FYE on or after 10/1/2009 (i.e. must use T.21 for FYE 10/1/2009 and after), except for the H1N1 Vaccine changes which are effective for services on or after 9/1/2009.

T.21 added three new ancillary cost centers, Cardiac Rehab, Hyperbaric Oxygen Therapy, and Lithotripsy. These will be available from our “pick list” of cost centers. W/S S-3 part I, line 26, columns 5.01, 5.02, 6.01, and 6.02, for Observation Bed Days, are N/A for FY Begin 10/1/2009 and after. No more “admitted” and not admitted split.

Total observation bed days will now be subtracted in the calculation of E part A, line 3 (bed days available). W/S E part A and L part I, line 4.01 or 5.01, are revised to INCLUDE in Total days, the Labor and Delivery Days from the NEW line 29 of S-3 part I. This is effective for FY Begin 10/1/2009 and after.

W/S S-2 line 21.01, column 2 was added for Pickle providers (“Y” indicates Pickle for operating DSH). If Pickle, then the allowable DSH percentage is automatically 35%, on E part A line 4.03.

W/S E-3 part I, lines 1.02, 1.04, 1.41, and 1.42 must be subscripted for column 1.01, if the FY overlaps 10/1/2009, as the LIP “factor” changed from 0.6229 to 0.4613. You only need to split payments on line 1.02 as we calculate the rest. W/S M-3 line 14 calculation is phasing out the “limit”, over 5 years. For services through 12/31/2009 the 62.5% limitation remains. For services 1/1/2010 to 12/31/2011, the limit is 68.75%. For services 1/1/2012 to 12/31/2012 the limit is 75%. For services 1/1/2013 to 12/31/2013 the limit is 81.25%. For services on or after 1/1/2014, the limit is zero, or 100% reimbursement.

W/S M-4 added columns 2.01 and 2.02 for the H1N1 vaccine. Medical Supply cost, Total injections, and Medicare injections must be split between Pneumococcal, Influenza, H1N1 Only, and Influenza and H1N1 combined.

For even more up-to-date news, visit Pete Harmon’s blog at http://www.hfssoft.com/blogs/pete/

HFS received CMS approval for T.20 on 9/17/2009.
See Pete Harmon’s blog for details…

On Friday, August 28, 2009 we sent additional HFS comments on the Draft 2552-10 to CMS. These additional comments were the result of having input numbers into the forms. These comments are available in PDF format: MORE HFS DRAFT 2552-10 COMMENTS

In general, we were disappointed that Title V and XIX are less accommodated in the 2552-10, instead of expanded, or left the same as in the 2552-96 (i.e. elimination of W/S C part II, which is still used by States; elimination of D-1 lines 66-82 in the 2552-96 for the per diem calculation, etc.). This will most likely result…

This spreadsheet contains a crosswalk comparison between the 2552-96 and 2552-10 form sets for worksheets A and S-2, including the new S-2 Part II.

As part of a national effort to raise the awareness of the importance of a complete and accurate Medicare Cost Report, HFS is part of a committee with the National Association of Home Care and Hospice (NAHC). We are trying to get this message out to all HHA cost report preparers, by distributing a news release published by NAHC in July 2009.

If CMS rebases the HHA rates, it will be the cost report that is used for the information. Thus, the more complete and accurate the information, the more likely accurate rates will be determined.

Please read the NAHC news release and share it with any HHA cost report preparer you may know. If you have any questions about this, please contact Pete Harmon, at (916)686-8152, or pete@hfssoft.com.