Month / Year
Subject

Category: CARES

September 30 Deadline for CARES PRF Reporting Period 3

CARES Provider Relief Fund Reporting Period 3
 
Reminder – providers have until Friday, September 30, to file for Reporting Period 3 (RP3) of the CARES Provider Relief Fund (PRF). Even if $0 PRF was received in RP3, HRSA still requires confirmation (of $0 payments) in the PRF Reporting Portal.   
 
PRF received in RP3 relates to payments (>$10K) received from January 1, 2021 through June 30, 2021.  The period of availability associated with these payments is January 1, 2020 through June 30, 2022. The period of availability reflects COVID-19 expenses and lost revenues that may be used toward recognizing RP3 PRF payments (provided these expenses and lost revenues were not previously used towards PRF in RP1 or RP2). Additional resources for RP3 reporting can be found here on HRSA’s website. 
 
Please contact Fred Fisher at fred.fisher@toyonassociates.com with any questions. 
Back to top

CMS Proposes New Cost Reporting Instructions

CMS recently released new proposed Medicare cost reporting instructions, available for download here on the CMS website. Comments are due to CMS on July 22, and Toyon will be sharing our comments with more details over the coming weeks.  
 
CMS is proposing notable cost report changes to the following:
  • Worksheet S-10 Uncompensated Care (UC) reporting for Federal Fiscal Year 2023 (beginning on/after 10/1/2022) and subsequent years.
    • Amongst other proposed revisions, CMS proposes a significant change that UC cost represents “only the general short-term hospital inpatient and outpatient services billable under the hospital CMS Certification Number (CCN).”
    • CMS proposes a standard Worksheet S-10 data format under Exhibit 3B and Exhibit 3C.
  • Empirical DSH Medicaid eligible days reported using Exhibit 3A, with applicable instructions to §4004.1 and requirements at 42 CFR 413.24(f)(5)(i)(C) starting with Federal Fiscal Year 2023 cost reports.
  • Medicare bad debt reporting using Exhibit 2A, with applicable instructions to §4004.2 and requirements at CFR 413.24(f)(5)(i)(B) starting with Federal Fiscal Year 2023 cost reports.
  • COVID-19 PHE temporary expansion bed reporting. New cost reporting line effective March 1, 2020 through the end of the COVID-19 PHE.
  • Worksheet D-4 Organ Acquisition updates and additions. 
    • CMS updates cost reporting instructions to reflect the codification for Medicare organ acquisition payment policies at transplant hospitals as included in FR 73416 (December 27, 2021).
    • For cost reporting periods beginning on or after October 1, 2022, CMS proposes providers separately identify revenue for organs sold associated with Medicare Secondary Payer (MSP organs, subscript of line 66) and a separate subscripted line (informational only) for the transplant payment portion.
    • For cost reporting periods beginning on or after October 1, 2022, CMS proposes providers separately identify organs transplanted into Medicare beneficiaries, kidneys transplanted into Medicare Advantage (MA) beneficiaries, organs transplanted as Medicare Secondary Payer, and organs transplanted for all other payers (subscript line 75).    
  • Worksheet D-6 Allogeneic Hematopoietic Stem Cell Transplant (HSCT) Acquisition Costs
    • CMS proposes further changes to this new worksheet series to calculate inpatient reimbursement for allogeneic stem cell acquisition costs associated with Federal Fiscal Year 2021 cost reports (beginning on or after 10/1/2020).
    • CMS proposes to apply key changes (from the initial PRA package issued in November 2020) which include basing payment on the ratio of Medicare transplants to total transplants and reporting all-payer charges related to donors (follows the same methodology as solid organ transplants).
Please feel free to share questions or suggestions for comments to Fred Fisher, fred.fisher@toyonsassociates.com. Specific to organ acquisition, please contact Robert Howey, robert.howey@toyonassociates.com.
 
Back to top

CARES PRF Update

CARES Phase 4 / Rural ARP Consideration

CARES PROVIDER RELIEF FUND (PRF)

Phase 4 and Rural ARP Reconsideration Update
Toyon is pleased to provide this update on the CARES Provider Relief Fund (PRF). Please feel free to contact Fred Fisher at 888.514.9312, fred.fisher@toyonassociates.com with any questions.
 
Providers in receipt of CARES Phase 4 and/or rural payments from the American Rescue Plan (ARP) have until May 2, 2022 to request a payment reconsideration. The reconsideration process is available to any provider looking to correct potential errors in their Phase 4 and/or Rural ARP payment according to HRSA’s methodology. HRSA will only consider correction of any errors; and will not consider changes to its payment methodology or policy in the reconsideration process. To request a Phase 4 and/Rural ARP reconsideration, providers must:
 
1) Review HRSA’s methodology. Providers may also contact HRSA at 866.569.3522 (TTY dial 711) to receive additional information on how Phase 4/Rural ARP payments were determined. 
 
2) Gather the following documents:
a. Payment determination letter from HRSA
b. DocuSign envelope ID for the ARP Rural/Phase 4 application
c. The contact information and Tax ID Number (TIN) included on the original Phase 4/ARP Rural application
d. The reason believed the Phase 4/Rural ARP payment was calculated incorrectly, (related to the PRF Phase 4 and ARP Rural Payment Methodology)
 
3) Complete and submit the PRF Reconsideration Request Form by 11:59:59 pm EST on May 2, 2022. HRSA states not to include any supplemental information or documentation beyond completing the PRF Reconsideration Request Form and uploading your Phase 4/ARP Rural payment determination letter. HRSA will only review your original submitted application and will request any clarifying information directly, as needed.
 
Providers expecting, but not yet in receipt of, CARES Phase 4 and/or Rural ARP payments will have 45 days to apply for reconsideration after receipt of a payment determination notice from HRSA. More information is available at HRSA’s PRF Reconsideration site as well as HRSA’s PRF Reconsideration FAQ site. Please also see Toyon’s updated CARES PRF Presentation (February 4) for information on recent CARES PRF allocationsPeriod 2 Reporting, and new FAQs issued January 27, 2022.
Back to top
Toyon Associates Healthcare Finance

Here TO HELP

Receive a no obligation consultation on how Toyon can help make your cost reporting simpler, easier, and trusted.