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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, firstname.lastname@example.org. Specific to organ acquisition, please contact Robert Howey, email@example.com.
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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. 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.
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
After entering above data, the template will compare:
- — FFY 2019 Audited WS S-10 vs. FFY 2019 WS S-10 per CMS HCRIS
- — 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
 Cost report fiscal years beginning on/after 10/1/2018 through 9/30/2019
 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).
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