HFS News & Information

CMS issued Transmittal 18 to the 2552-10 on December 29^th, 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

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

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

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

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.