Medicare Archives

Comments on Proposed Cost Reporting Instructions

July 15, 2022

CMS recently released new proposed Medicare cost reporting instructions, available for download here on the CMS website. Comments are due to CMS by July 22, and can be submitted electronically at this link.

Please see Toyon’s comments on CMS’s proposed cost report instructions here. Additionally, to assist with comments to CMS, providers may download the Hospital | Health System template here. Please review all comments prior to submitting, and feel free to use some or all of the content in this letter. Providers may also amend the language to best articulate comments to CMS using hospital-specific examples, etc.

Toyon comments on the following:

Worksheet S-2 Lines 24 and 25: Medicaid DSH Eligible Days
Worksheet S-2 Line 89: TEFRA Adjustment Date
Worksheet S-2 Line 123: Purchased Administrative Services
Exhibit 2A: Listing of Medicare Bad Debts
Exhibit 3A: Listing of Medicaid Eligible Days for DSH Eligible Hospitals
Worksheet S-10: Financial Assistance Policies
Worksheet S-10: Acute Care Only
Worksheet S-10: Medically Necessary Healthcare
Worksheet S-10: Uninsured Charity Care
Worksheet S-10: Insured Charity Care
Worksheet S-10: Inferred Contractual Relationships
Worksheet S-10: Total Bad Debt
Exhibit 3B (Charity Care Listing)
Exhibit 3C (Listing of Total Bad Debts)

Worksheet S-10 UC DSH

Amongst other proposed revisions, CMS calls for providers to report Uncompensated Care (UC) costs for acute care services only (based on hospital Medicare provider number) on Worksheet S-10 Part II. Please note Section IV of the Hospital | Health System template requests CMS to omit this reporting requirement, as delineating Worksheet S-10 UC cost between acute care and sub-acute care adds another administrative burden to Worksheet S-10 reporting. Toyon acknowledges the reporting of acute care only for UC DSH payments may result in a shift in UC DSH payments for certain hospitals (depending on whether a DSH provider has material charity and bad debt related to subacute providers). Toyon is not commenting on a potential shift in payments, and only focuses on the additional administrative effort of collecting and reporting Worksheet S-10 data.

Organ Acquisition Changes

Toyon is not commenting on CMS’s proposed changes related to Organ Acquisition reporting and reimbursement. Toyon agrees with CMS’s proposed changes, which were also included in the previous PRA package from November 2020. Listed below are CMS’s proposed changes related to Organ Acquisition.

Worksheet A, Lines 78 and 102

CMS is adding lines 78 (CAR T-Cell Immunotherapy) and 102 (Opioid Treatment Program), which will require hospitals to create separate G/L departments to track these expenses and charges. Line 78 is used for reporting IPPS (D-3) and OPPS (D Part V) charges from the PS&R. Line 102 is informational only and is not included in the PS&R charges.

Worksheet D-6 series

This is a new form used to obtain cost-based reimbursement for allogeneic stem cell acquisition costs. CMS made several noteworthy updates to this form from the previous PRA in November 2020. First, there’s no longer a checkbox to include CAR T-Cell acquisition costs in this section which was to be reported for informational purposes only (see comment above for Worksheet A line 78).

Second, the Medicare reimbursement for allogeneic stem cell acquisition costs will now be based on the ratio of Medicare to total transplants, much like the methodology for solid organ. Previously, the form required only to include donor charges for Medicare recipients to determine the Medicare portion. Worksheet D-6 (Part I) now requires hospitals to capture donor charges for all payers. This methodology is a departure from the CMS comments in the FFY 2019 IPPS Final Rule, so CMS may issue a separate rule with comment period for this change.

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Please feel free to share questions to Fred Fisher, fred.fisher@toyonassociates.com. Specific to Organ Acquisition reimbursement, please contact Robert Howey at robert.howey@toyonassociates.com.

FFY 2023 IPPS PROPOSED RULE COMMENTS DUE JUNE 17, 5 PM EDT

June 14, 2022

This Friday June 17^th at 5 PM, comments are due on CMS’s proposed FFY 2023 IPPS rate setting. In commenting –

Refer to file code CMS–1771–P.
Submit electronically through this regulation link then select the COMMENT button at left, below the title; or
Submitted by mail to: Centers for Medicare &Medicaid Services, Department of Health and Human Services, Attention: CMS–1771–P, P.O. Box 8013, Baltimore, MD 21244–1850.

Please feel free to see Toyon’s comments here on our website. Providers may also download a word version of these comments with designated [highlighted] areas to populate for your hospital or health system.

Toyon’s comments are focused on reimbursement issues, as well as cost reporting proposals requiring additional clarification, as summarized in the table below.

#	Issue	FFY 2023 Proposal	Summarized Comment
1	Market Basket	2.7% Update 3.1% Market Basket -0.4% ACA Adjustment	8.0% Update Based on recent Medicare cost increases[1]
2	Outliers	$43,214 Fixed Loss Threshold (40% increase from PY)	Reduce threshold in anticipation of fewer COVID-19 hospitalizations in FFY 2023
3	UC DSH Factor 1	-$542M Reduction to FFY 2023 UC DSH Payments	-$542M Reduction to FFY 2023 UC DSH Payments Increase Factor 1 discharge adjustment considering forecasts of increased Medicare utilization
4	UC DSH Factor 2	65.71% -0.03 from prior yr -0.07 from penultimate yr	65.71% -0.03 from prior yr -0.07 from penultimate yr Increase Factor 2 to reflect projections of increases to the national uninsured population
5	Empirical DSH Section 1115 Waiver Days	Medicaid patients regarded as eligible from 1115 Waiver w/ essential health benefits (EHB)	Clarification on premium assistance days “for which the premium assistance is equal to or greater than 90 percent of the cost of the coverage”
6	NP95 Respirator Payments	Reimbursement for the incremental cost of using wholly domestically produced N95 respirators	Supported and request CMS reimburse for all patients (not only Medicare) in bi-weekly lump sum payments

Please feel free to email Fred Fisher at fred.fisher@toyonassociates.com with any questions.

[1] Analysis of Medicare cost per discharge change from FFY 2019 to FFY 2020 per Medicare cost report data from the Healthcare Cost Report Information System (HCRIS). Medicare cost per Worksheet D-1 Part II, Line 49, Column 1. Medicare discharges per Worksheet S-3 Part I L14.00 C13.00.

You’re Invited – FFY 2023 IPPS PROPOSED RULE WEBINAR

April 25, 2022

Save the Date!

Toyon University® Presents:

The FFY 2023 IPPS

Proposed Rule

You and your team are invited to Toyon’s open webinar on the FFY 2023 IPPS Proposed Rule May 20, from 10 a.m. PDT to 11 a.m. PDT.

To sign up for the IPPS Proposed Rule Webinar, please register here.

The Proposed FFY 2023 IPPS webinar will include analysis, insight, and recommended comments on CMS’s proposed rates including empirical DSH, Uncompensated Care DSH, Graduate Medical Education, Wage Index, and data impacted by COVID-19 affecting Medicare payments.

Toyon will be providing a written summary of the FFY 2023 IPPS Proposed Rule prior to this webinar. Please feel free to email Fred Fisher at fred.fisher@toyonassociates.com with any questions or topics of interest for your hospital(s).

Toyon Analytics – FFY 2023 IPPS Proposed Rule

Toyon is pleased to provide complimentary access to estimated hospital payments per the Medicare Federal Fiscal Year (FFY) 2023 IPPS Proposed Rule via an interactive dashboard here.

Please feel free to email Fred Fisher at fred.fisher@toyonassociates.com with any questions on this forthcoming analysis.

Category: Medicare

Comments on Proposed Cost Reporting Instructions

FFY 2023 IPPS PROPOSED RULE COMMENTS DUE JUNE 17, 5 PM EDT

You’re Invited – FFY 2023 IPPS PROPOSED RULE WEBINAR

Here TO HELP