HFS News & Information

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.

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.

The HHA, 1728-94 was updated to Transmittal 17 by CMS, on October 7, 2016. Transmittal 17 is effective for cost reporting periods beginning on or after October 1, 2015. HFS was approved for Transmittal 17 on January 30, 2017 and anticipates the release of updated software February 10, 2017. HFS will be hosting a WebEx on the 1728-94 Changes, System release and other updates on March 1, 2017.

Transmittal 17 was primarily to implement the statutory requirement for hospice payment reform in §3132 of the Patient Protection and Affordable Care Act (ACA) and to incorporate data previously reported on the Provider Cost Report Reimbursement Questionnaire, Form CMS-339.

Changes include:

• Addition of Worksheet S-2-1, to include questions previously required in Form CMS-339
• Removed obsolete Worksheets S-6 and J-1 through J-4.
• Removed obsolete Worksheets RH-1 through RH-2.
• Removed obsolete Worksheets FQ-1 through FQ-2.
• Addition of Worksheets S-5 Parts III & IV and Worksheets O through O-8 for any HHA based hospice with a cost reporting period beginning on or after October 1, 2015 AND ENDING on or after September 30, 2016.
• Effective for cost reporting periods beginning on or after October 1, 2014, HHA-based FQHCs will be required to complete a separate Form CMS-224-14.

This release updates the HFS 1728-94 to the HFS .mcrx file format and updated platform.  This is backwards compatible.  Users will receive notification when opening their existing .mcr files that the files will be converted to the new platform.  No data will be lost and the user functionality will be the same.  Of course, if you have any problems please contact us right away.

The transmittal is available at the CMS website:

https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2016-Transmittals-Items/R17p232.html?DLPage=2&DLEntries=10&DLFilter=R17&DLSort=1&DLSortDir=ascending

On September 4, 2015, CMS issued a Federal Register notice releasing a draft of revisions to the HHA Cost Report. The new draft form revisions are being proposed to accommodate the statutory requirement for hospice payment reform and the statutory requirement establishing a prospective payment system for Federally Qualified Health Centers in the ACA.

This draft was recently made available at the CMS website:

https://www.cms.gov/Regulations-and-Guidance/Legislation/PaperworkReductionActof1995/PRA-Listing-Items/CMS-1728-94.html?DLPage=1&DLEntries=10&DLSort=1&DLSortDir=descending

Major proposed changes include:

• CMS is proposing that effective for cost reporting periods beginning on or after October 1, 2014, HHA-based FQHCs would be required to complete the proposed free-standing Form CMS-224-14.
• CMS is proposing to add a Worksheet S-2-1, to replace the current requirement to file a separate Form CMS-339.
• CMS is proposing to eliminate the J Series, previously used for the reporting of Home Health based CORF services.
• CMS is proposing to add Worksheet S-5, Parts III and IV, to implement the new reporting for Hospice services effective for cost reporting periods beginning on or after October 1, 2015.
• CMS is proposing to add an O Series of Worksheets, to implement the new reporting for Hospice services effective for cost reporting periods beginning on or after October 1, 2015.

If you wish to comment on this draft, you may do so until November 3, 2015 at the following website:

http://www.regulations.gov/#!documentDetail;D=CMS_FRDOC_0001-1767

On October 24th, 2014, CMS issued Transmittal number 8 to the Provider Cost Reporting Forms and Instructions, Chapter 11, Form CMS-339. Transmittal 8 is effective for cost reporting periods ending on or after September 30, 2014.

The transmittal is available at the CMS website:

http://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2014-Transmittals-Items/R8P211.html?DLPage=1&DLFilter=339&DLSort=1&DLSortDir=ascending

Form CMS 339 is ONLY to be completed by Home Health Agencies, Community Mental Health Centers, Rural Health Clinics, Federally Qualified Health Centers, Hospices (With cost reporting periods beginning prior to October 1, 2014) and Organ Procurement Organizations (OPOs) submitting cost reports to the Medicare Administrative Contractor.

The Form CMS-339 was significantly streamlined to eliminate requirements and exhibits that were previously required for hospital providers. The 339 questions have been incorporated directly into the new Hospital, SNF, ESRD and Hospice cost reporting forms.

HFS has programmed the software changes for transmittal 8 and was approved by CMS on January 23, 2015, HFS will make the update available to users of the software in our February 6, 2015 software update.

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

On Friday, August 22^nd , 2014, CMS issued Transmittal number 1 to the Provider Cost Reporting Forms and Instructions, Chapter 43, Form CMS-1984-14. Form CMS-1984-14 is the new Hospice Cost Report for free-standing Hospice providers effective for cost reporting periods beginning on or after October 1, 2014.

The transmittal is available at the CMS website:

http://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2014-Transmittals-Items/R1P243.html?DLPage=2&DLSort=1&DLSortDir=descending

HFS has completed the programming of the new form set and has submitted a test case to CMS for approval.  We anticipate approval in the near future. Once approved, HFS will make the new form set available to users of the Hospice Form CMS-1984 software.

Major changes from the previous 1984-99 and the new 1984-14 include:

• Date previously reported on the Provider Cost Report Reimbursement Questionnaire, Form CMS-339, has been incorporated into a Worksheet S-2.
• The Worksheet A and B series will now require the separate identification and reporting of patient care service costs by level of care (Continuous Home Care, Routine Home Care, Inpatient Respite Care and General Inpatient)

HFS anticipates scheduling WebEx sessions on the new form sets and software once approved and ready for distribution.  Information regarding the sessions will be distributed to all hospice software users when available.

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

Sequestration is effective for Services rendered on or after 4/1/2013. It will be prorated for FYE overlapping 4/1/2013 (e.g. a 6/30/2013 FYE has 91 days of Sequestration, so 91/365, times 2%, will be the reduction percentage, or about .50%). Bad Debt changes are effective for FY Begin 10/1/2012 and after, so a 7/1/2012 to 6/30/2013 FY is not affected.

We are awaiting the Hospital (2552-10) Transmittal #4 from CMS, which is to have the Sequestration and Bad Debt Changes (as well as other changes for the ACA). CMS has not released a draft of T-4 as of 7/25/2013. This will be our Version 4.x.x.x.

We received Transmittal #5 for the 2540-10 (SNF), which incorporated the Sequestration and Bad Debt changes. We have submitted a test case and are awaiting CMS approval of our system. This will be our Version 5.x.x.x.

We received Transmittal #2 for the 265-11 (ESRD), which incorporated the Sequestration and Bad Debt changes. We have submitted a test case and are awaiting CMS approval of our system. This will be our Version 2.x.x.x.

We received Transmittal #16 for the 1728-94 (HHA), which incorporated the Sequestration and Bad Debt changes. We have submitted a test case and are awaiting CMS approval of our system. This will be our Version 16.x.x.x.

We received Transmittal #11 for the 222-92 (RHC/FQHC), which incorporated the Sequestration and Bad Debt changes. We have submitted a test case and are awaiting CMS approval of our system. This will be our Version 11.x.x.x.

We received Transmittal #8/9 for the 2088-92 (CMHC), which incorporated the Sequestration and Bad Debt changes. We have submitted a test case and are awaiting CMS approval of our system. This will be our Version 9.x.x.x.

The 216-94, OPO system, is the only approved system “on the street” with the Sequestration changes incorporated (Bad Debt is N/A). This is our Version 5.4.145.0.

CMS released a Draft of the new Hospice, 1984-14 forms and instructions for industry comments 5/29/2013. This is to be effective for FY Begin 1/1/2014 and after. Once comments are addressed and CMS issues the Final, we will know more about what changes are to be made.

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.

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.