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.

The Centers for Medicare & Medicaid Services (CMS) released an additional list of Frequently Asked Questions (FAQs) to Medicare providers regarding the Department of Health & Human Services’ (HHS) Provider Relief Fund and the Small Business Administration’s Paycheck Protection Program payments, also referred to as coronavirus disease 2019 (COVID-19) relief payments.  The FAQs provide guidance to providers on how to report provider relief fund payments, uninsured charges reimbursed through the Uninsured Program administered by Health Resources and Services Administration, and Small Business Administration (SBA) Loan Forgiveness amounts. The FAQs also address that provider relief fund payments should not offset expenses on the Medicare Cost Report.

The full FAQ can be found at the below link and the cost reporting questions begin on page 98. Please note that the FAQ did not further extend cost report filing extensions past those published on July 15, 2020.

https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf

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.

CMS has directed MACs to further extend the cost reporting deadlines for the following cost reporting fiscal year ends for all provider types:

* Please note these are new extensions.

While we have been told that CMS is considering the 3-31-2020 FYE providers that are currently due 8-31-2020, no extension has been posted at this time.

Please contact HFS Support support@hfssoft.com, for any comments or questions.

CMS published a preliminary Public Use File (PUF) for the FY 2022 wage Index May 18, 2020. This file reflects the Worksheet S-3, Parts II and III wage data from cost reports for Fiscal Year (FY) 2018 (FY Beginning from 10/1/17 to 9/30/2018).

The following file has been created and can be downloaded and used with the Wage Index Verification Tool for the Federal Fiscal Year 2022, Preliminary PUF:

FY_2022_Prelim_S3 wage tab_05182020.csv

CMS published the Proposed Rule Public Use File (PUF) for the FY 2021 wage index and occupational mix on 4/30/2020. This file reflects the Worksheet S-3, Parts II and III wage data from cost reports for Fiscal Year (FY) 2017 (FY Beginning from 10/1/16 to 9/30/2017). 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 2021 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 29, 2020.

The following file has been created and can be downloaded and used with the Wage Index Verification Tool for the Federal Fiscal Year 2021, Preliminary PUF:

FY_2021_April_30_2020_S3_Data_PUF.csv

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 a proposed Public Use File (PUF) for the FY 2021 wage Index January 31, 2020. This file reflects the Worksheet S-3, Parts II and III wage data from cost reports for Fiscal Year (FY) 2017 (FY Beginning from 10/1/16 to 9/30/2017).  Per the CMS notice “All requests from hospitals for corrections to their FY 2021 wage index data must be submitted to and received by their Medicare Administrative Contractors (MACs) on or before February 14, 2020.“

The following file has been created and can be downloaded and used with the Wage Index Verification Tool for the Federal Fiscal Year 2021, Proposed PUF:

FY_2021_January_31_2020_S3_Data_PUF.csv

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