HFS News & 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 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

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.

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 approved our new ESRD 265-11 Medicare cost report software on January 30, 2011. We will release the full version of the software on February 3, 2012. You can download the full version of the software from the download page on our website. You can use the new software to prepare and electronically file your cost report(s). Any cost report file(s) you created with the beta version will work with the new full version of the 265-11 software.

Please note the new file extension for the 265-11 cost report data files is .mcrx. You will be able to open both 265-94 and 264-11 cost report using the yellow icon HFS software. Both the 265-11 and 265-94 systems are installed in the same folder and both start with the same yellow HFS icon-shortcut.

The use template option is not yet operational. We will get the template feature up and running as soon as possible, but currently you will only be able to open a blank, new 265-11 cost report.

Effective Dates (January 1, 2011 and after)
Form CMS-265-11 must be completed by all independent end stage renal dialysis (ESRD) facilities that are not hospital-based for cost reporting periods ending on or after January 1, 2011.

Extended Filing Deadlines for 265-11 Cost Reports
CMS recently extended the filing deadline for ESRD 265-11 cost reports. The following table contains the new cost report due dates.

On July 27, 2011 HFS received a memorandum from CMS regarding filing deadlines for SNFs. The following is a summary of the details we received.

The 2540-10 is effective for cost reporting periods beginning on or after 12/01/2010. For any short period cost reports beginning on or after 12/01/2010 and ending 11/30/2011, providers will continue to file on the form CMS-2540-96. No extensions are proposed at this time.

by Chuck Briggs

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.