1. COVID-19 Funding Duplication
Recommendation to create a new payor code for HRSA’s uninsured program and associated charge write-offs.

2. HRSA’s COVID-19 Uninsured Program
Recommendation to follow FAP procedures to determine insurance status of a patient.

3. FFY 2018 S-10 Audit Update
CMS is reducing the number of hospitals selected for FFY 2018 S-10 audits.

4. DSH | UCC Used for $2bn in Funding
HHS is including DSH and UCC in $2bn of CARES funding for eligible COVID-19 High Impact Providers.


Toyon’s Uncompensated Care Recognition Services (UCRS) is pleased to provide this update on Medicare Uncompensated Care (UC) DSH.  For more information, please contact Fred Fisher at 888.514.9312,  fred.fisher@toyonassociates.com.

1. Avoiding COVID-19 Funding Duplication

The Terms and Conditions (T&C) for providers accepting CARES Funding do not allow duplication of payment from federal or state UC DSH[1]Toyon recommends hospitals  establish new payor codes associated with all patients submitted for reimbursement from HRSA’s Uninsured Program.  This payor code can be used to identify COVID-19 patients to exclude from the Medicare cost report WS S-10 and the accompanying UC DSH listing.

2. Claims for HRSA’s Uninsured COVID-19 Program

Hospitals providing COVID-19 testing/treatment will be reimbursed at Medicare rates[2] for service dates on or after 2/4/2020.  Toyon recommends hospitals follow procedures per their patient financial assistance policy(s) in determining the insurance status of a patient at the time services were provided.  This may include checking for patient eligibility based on information obtained from the patient.

HHS and HRSA state the following concerning the determination of uninsured patients:

  • You have checked for health care coverage eligibility and confirmed that the patient is uninsured. You have verified that the patient does not have coverage such as individual, employer-sponsored, Medicare or Medicaid coverage, and no other payer will reimburse you for COVID-19 testing and/or care for that patient.[3]
  • The Recipient plans to submit claims for reimbursement for care or treatment related to positive diagnoses of COVID-19 provided to individuals who do not have any health care coverage at the time the services were provided.[4]
  • FFCRA Uninsured Individuals means individuals who, as of the date of service for which Recipient seeks Payment, are not enrolled in:
    • A Federal health care program[5], including an individual who is eligible for medical assistance[6]; or
    • A group health plan or health insurance coverage offered by a health insurance issuer in the group or individual market.[7] [8]

3. FFY 2018 S-10 Audit Update

Toyon confirmed CMS is reducing the number of providers selected for FFY 2018 audits this year (as opposed to auditing all DSH hospitals, – it appears, like prior years – only certain DSH hospitals will be audited for FFY 2018).  Per CMS’s New Flexibilities and Waivers, CMS states:

“The agency will continue to engage in oversight activities but will suspend requesting additional information from providers, healthcare facilities, Medicare Advantage and Part D prescription drug plans, and States.” 

Toyon will continue to monitor these changes and provide any updates on CMS’ revised FFY 2018 S-10 audit plans. 

4. Disproportionate Share and UCC Data Used in CARES Funding

HHS is adding $2 billion (to $10 Billion of High Impact CARES Funding) based on hospital “Medicare and Medicaid disproportionate share and uncompensated care payments”.  HHS is distributing $12 billion to 395 hospitals who provided inpatient care for 100 or more COVID-19 patients through April 10, 2020.  Eligible hospitals are paid “a fixed amount per COVID-19 inpatient admission, with an additional amount taking into account their Medicare and Medicaid disproportionate share and uncompensated care payments”.  Toyon will provide more information on these details as they are made available. 

Toyon is committed to apprising providers with important reimbursement updates and will keep you updated with the latest on UC DSH and COVID-19 funding and documentation.  Please feel free to visit Toyon’s COVID-19 Resources for updates on hospital funding estimates, and recommendations on documenting cost and revenue losses associated with this public health emergency.  Please contact Fred Fisher at 888.514.9312 or fred.fisher@toyonassociates.com if you have any questions. 

[1] Per Uninsured Program Terms and Conditions –  “The Recipient certifies that it will not use the Payment to reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse…The Recipient will not include costs for which Payment was received in cost reports or otherwise seek uncompensated care reimbursement through federal or state programs for items or services for which Payment was received.”

[2] Per HRSA’s Uninsured Program FAQs – “Subject to available funding…For purposes of this program, facility reimbursement based on IPPS will not include the 20% increase to the DRG weight for COVID-19 diagnoses U07.1 and B97.29 authorized by Section 3710 of the Cares Act.”

[3] HRSA’s Uninsured Program

[4] HRSA’s Terms for Treatment (Page 1, first bullet)

[5]  As defined under section 1128B(f) of the Social Security Act (42 U.S.C. 1320a-7b(f))

[6]  Eligible only because of subsection(a)(10)(A)(ii)(XXIII) of Section 1902 of the Social Security Act

[7] Terms are defined in section 2791 of the Public Health Service Act (42 U.S.C.300gg-91)), or a health plan offered under chapter 89 of title 5, United States Code.

[8] HRSA’s Terms for Testing (page 2, second sub-note)

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