Month / Year

Subject

Category: S-10

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.

# # # #

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.

CMS Proposes New Cost Reporting Instructions

June 27, 2022

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.

FFY 2019 Worksheet S-10 Audit Verification

February 11, 2022

CMS recently released updated Medicare cost report data in the Healthcare Cost Report Information System (HCRIS) including updates to Federal Fiscal Year (FFY) 2019 Worksheet (WS) S-10^[1]. Toyon recommends Disproportionate Share (DSH) providers validate this HCRIS information, as CMS will likely use FFY 2019 WS S-10 data to determine FFY 2023 Uncompensated Care DSH (UC DSH) payments.

Toyon also recommends providers contact their MAC regarding any discrepancies between their FFY 2019 WS S-10 audit results and the HCRIS data. Toyon will provide this service for all our S-10 clients to verify the agreed upon audit results were transmitted accurately. CMS’s use of FFY 2019 WS S-10 data will be further discussed in the FFY 2023 IPPS Proposed Rule this Spring.

Toyon’s FFY 2019 WS S-10 Audit Verification File Available HERE

To assist with audit verification, please feel free to download (using the link above) Toyon’s WS S-10 comparison file. This file allows providers to enter the results from their WS S-10 audit adjustment reports and compare against WS S-10 data in CMS’s HCRIS database.

File Use

All data entry areas in the template are orange.

Enter Medicare provider number in Excel Cell A2
Enter FFY 2019 WS S-10 audit results in the following cells
- Cell J26 – WS S-10 Line 1, Col 1: Cost to Charge Ratio
- Cell H30 – WS S-10 Line 20, Col 1: Uninsured Charity Charges
- Cell I30 – WS S-10 Line 20, Col 2: Insured Charity Charges
- Cell H32 – WS S-10 Line 22, Col 1: Uninsured Charity Payments, if applicable
- Cell I32 – WS S-10 Line 22, Col 2: Insured Charity Payments, if applicable
- Cell J39 – WS S-10 Line 25, Col 1: Medicaid Charges > LOS Limit, if appliable
- Cell J40 – WS S-10 Line 26, Col 1: Total Bad Debt Expense
- Cell J42 – WS S-10 Line 27.01, Col 1: Allowable Medicare Bad Debts

File Results

After entering above data, the template will compare:

— FFY 2019 Audited WS S-10 vs. FFY 2019 WS S-10 per CMS HCRIS^[2]
— FFY 2019 Audited WS S-10 vs. FFY 2018 Audited WS S-10 per CMS HCRIS

Should you have any questions about the audit comparison file and/or questions about your hospital’s audit results please feel to reach out to Liam Corrigan-Carias at 888.514.9312, Liam.Corrigan-Carias@toyonassociates.com

_______

^[1] Cost report fiscal years beginning on/after 10/1/2018 through 9/30/2019

^[2] It is possible that Cost of Uncompensated Care on Line 30 may vary from the S-10 audit results. This may be a result of separate cost report audits impacting the Cost to Charge Ratio (S-10, Line 1) or Medicare Bad Debts (S-10, Line 27.01).

Here TO HELP

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