Month / Year

Category: Medicare

Transmittal 18 New Cost Reporting Instructions – Section VI. Organ Acquisition

Key changes related to Organ Acquisition reimbursement include the following: 
Additional Subscripted Lines for Worksheet D-4, Parts III and IV 
Line 66 (Revenue for Organs Sold) is subscripted into two lines to separately report the Medicare Secondary Payer (MSP) organs primary payer payments between organ acquisition (line 66.01) and transplant (line 66.02 for informational purposes only). 
Line 75 (Organ Transplants) is subscripted into four lines to further identify transplants for Medicare beneficiaries (line 75.01), kidneys transplanted into Medicare Advantage beneficiaries (line 75.02), MSP organs (line 75.03), and all other payer transplants (line 75.04). 
Toyon’s take: The information for the new subscripted lines should already be included in the documentation, and the transition should require minimal adjustment. 
New Worksheet D-6 series (effective for cost reporting periods beginning on or after 10/1/2020) 
Transmittal 18 releases D-6 as a new form used to obtain cost-based reimbursement for inpatient allogeneic stem cell acquisition costs. Medicare’s reimbursement will be based on the ratio of Medicare to total transplants, much like the methodology for solid organ but only for inpatient HSCT transplants. 
Toyon’s take: If your hospital is new to this cost-based reimbursement methodology for acquisition costs, this requires collaboration with Revenue Cycle for identifying internal hospital charges for prospective and actual live donors for allogeneic stem cell transplants (all payers). The donors’ insurance defaults to that of the recipient and charges for Medicare beneficiaries should not be billed directly to Medicare. Also, review the departments mapped to line 77 to confirm the expenses meet the definition for allogeneic stem cell acquisition.
For further information, please contact Robert Howey at 888.514.9312 or
Back to top

Transmittal 18 New Cost Reporting Instructions – Section VII. Other Notable Changes and Clarifications

Other notable changes and clarifications in Transmittal 18 include, but are not limited to, the following: 
  • Identification of providers purchasing greater than 50% of its professional services from an unrelated organization located outside the main hospital’s local area labor market (WS S-2 Line 123) 
  • New Worksheet A lines for CAR T-cells (line 78) and Medicare-enrolled opioid treatment program (line 102) 
  • Clarification of Non-Chargeable Drugs Charged to Patients (WS A Line 73) 
  • Sequestration calculation in the cost report settlement schedules during and after the Protecting Medicare and American Farmers from Sequester Cuts Act of 2021 (PAMA). 
  • Information collection for the Community Health Access and Rural Transformation (CHART) model  
  • Renal Dialysis costs for pediatrics and Maintenance AKI (WS I series) 
  • End Stage Renal Disease (ESRD) payment information (WS I-5 Part III) 
  • Extension of the relaxed low volume adjustment requirements and Medicare Dependent Hospital (MDH) status through December 23, 2024, in accordance with sections 4101 and 4102 of the Consolidated Appropriates Act, 2023.
  • Recording of permanent adjustments to the TEFRA target amount per discharge 
  • MAC Outlier Reconciliation at Tentative Settlement (Worksheet E-5) 
Toyon’s take: Although the new Worksheet S-2 question on purchased services outside a hospital’s local labor market area seems informational on the surface, this information may be used for reimbursement purposes going forward. Per the OMB response to initial comments, the data collected is to “obtain a more recent estimate of the proportion of legal, accounting and auditing, engineering, and management consulting services that meet our definition of labor-related services.” The OMB also notes “the requested information ultimately impacts the labor-related share of the wage index for IPPS hospitals, as well as the labor-related share for inpatient rehabilitation facility, inpatient psychiatric facility, and long-term care hospitals.”   
For further information, please contact Robert Howey at 888.514.9312 or
Back to top

FFY 2024 IPPS Proposed Rule

On April 10, the Centers for Medicare & Medicaid Services (CMS) published the FFY 2024 IPPS Proposed Rule (effective for discharges on or after October 1, 2023). Comments are due to CMS by Friday, June 9 via (see instructions under the “submit a comment” tab and reference file code “CMS-1785-P”). Toyon will share our comment letter in the coming weeks. 
Toyon is pleased to provide our summary of the IPPS Proposed Rule, focused on areas directly impacting Medicare cost reporting and reimbursement for acute care hospitals. On Toyon’s website below, the topics are broken down in the following sections:
Contents – Breakdown of the FFY 2024 IPPS Proposed Rule 
Back to top
Toyon Associates Healthcare Finance


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