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FFY 2019 Worksheet S-10 Audit Verification

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
 
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[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).  
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Federal Year 2023 Wage Index Verification

FY 2023 January Public Use File (PUF) Release
On January 28, 2022, CMS released the latest FY 2023 wage index PUF, which includes revised FY 2023 wage index and occupational mix data for cost report periods beginning on or after October 1, 2018. The January PUF data should reflect the wage index data as reported on worksheets S-3, Pt. II-IV that was previously desk reviewed and verified by the Medicare Administrative Contractors (MAC). This PUF represents the second of three PUFs that CMS will issue to develop the FY 2023 hospital wage index and represents the most important PUF to review for accuracy of the revised data. Providers have until February 15, 2022 to request revisions to data as published in the January PUF. Corrections due to errors and/or mishandling of the wage index data, or revisions to desk review adjustments should be submitted to the provider’s MAC no later than this date. Supporting documentation must accompany any rebuttal requests and be sent directly to your MAC’s wage index contact.
 
As stated in the FY 2023 Hospital Wage Index Development Timetable released by CMS, the MACs have until March 18, 2022 to review and revise the wage index data as a result of a rebuttal request. However, since the next (and final) PUF will not be released until April 29, 2022, providers will need to be in touch with their MACs to determine if an appeal of their wage index data is necessary. According to the timetable, the deadline for hospitals to appeal MAC determinations and request CMS’s intervention in cases where the hospital disagrees with the MAC’s determination is April 1, 2022. The FY 2023 Wage Index Development Timetable can be located here for more information regarding the appeal process and requirements.
 
Toyon’s PUF Verification File Available HERE
Toyon has available (using the link above) a formatted PUF comparison file that includes the FY 2023 January PUF data, the initial (as-filed) FY 2023 PUF data as well as final FY 2022 wage index data to compare your hospital’s overall Average Hourly Wage (AHW). The file contains two tabs, one with the January PUF AHW comparison analysis and the other with a Medicare Occupational Mix Adjustment analysis. The second tab includes the Medicare Occupational Mix Adjustment analysis, although unless your hospital’s Occupational Mix data was revised, there should be no change from the previous year’s data.
 
Should you have any questions about the PUF comparison file and/or questions about your hospital’s AHW results, please feel free to reach out to Ryan Sader at 888.514.9312, ryan.sader@toyonassociates.com.
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Final Payment Rules – Calendar Year (CY) 2022

On November 2, 2021, the Centers for Medicare & Medicaid Services (CMS) issued the final rules for Calendar Year (CY) 2022 Outpatient Prospective Payment System (OPPS), CY 2022 Physician Fee Schedule, and CY 2022 Home Health PPS.

KEY UPDATES FROM THE CY 2022 OPPS FINAL RULE:
CY 2022 Medicare Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System Final Rule (CMS-1753-FC).
 
OPPS & ASC Payment Rates
Both the OPPS and ASC payment rates for hospitals that meet applicable quality reporting requirements will be increased by 2.0 percent (2.7 percent less 0.7 percentage point productivity adjustment.
 
Price Transparency
Proposed Increase in Civil Monetary Penalties (CMP) for noncompliance will be scaled by bed size (range $109,500 to $2,007,500 per hospital). Smaller hospitals with 30 or fewer beds are subject to a fine equal to $300 per day. Hospitals with a bed count between 31-550 beds are subject to a fine between $310 to $550 per day with a maximum penalty $2,007,500. Hospitals with a bed count of 551 or greater beds, are subject to a fine equal to $2,007,500 per hospital.
 
CMS is also requiring machine-readable files are accessible for automated searches and direct downloads.
 
Toyon’s Take
These fines emphasize CMS’s push to provide public access to pricing information.
 
Use of CY 2019 Claims Data for CY 2022 OPPS/ASC Ratesetting
CMS believes the best available data for projecting expected cost and OPPS/ASC payment derives from calendar year 2019, prior to the COVID-19 Public Health Emergency (PHE). Conventionally, CMS would have used the most recent data (from 2020) for ratesetting.
 
Toyon’s Take
Toyon recommends providers regularly evaluate CY 2022 OPPS/ASC payments to ascertain the reasonableness of CMS’s projection that CY 2022 cost and volumes will be more reflective of 2019 levels as compared to 2020. When areas of the country “normalize” from COVID-19 PHE, then it is best to use data from prior to the outbreak to project CY 2022 OPPS/ASC payments. Notably, CY 2020 data may not be used in future rates.
 
Changes to the Medicare Inpatient Only (IPO) List
In CY 2022 CMS will add back all codes to the IPO list, except CPT codes 22630 (Lumbar spine fusion), 23472 (Reconstruct shoulder joint), 27702 (Reconstruct ankle joint) and their corresponding anesthesia codes. Also, the planned elimination of the IPO list will be put on hold until further notice. See this link.
 
Toyon’s Take
Requiring certain services as inpatient only is a noteworthy change in course from the CY 2021 OPPS/ASC final rule initially eliminating 298 services from the IPO list. CY 2021 was also scheduled to be year one of a three-year process to phase out the entire IPO list. However, CMS listened to stakeholder comments and agrees patient safety is the main concern. Medicare continuously desires to provide their beneficiaries a choice, therefore is using additional time to review procedures and outcomes of IPO services.
 
OPPS and 340B
CMS is continuing to pay hospitals 22.5 percent less the Average Sales Price (ASP) for select 340B drugs.
 
Click here for the link to the display copy of the OPPS/ASC final rule; the document is scheduled to be published in the federal register on 11/16/2021.

 
KEY UPDATES FROM THE CY 2022 PHYSICIAN FEE SCHEDULE FINAL RULE:
CY 2022 Medicare Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System Final Rule (CMS-1751-F).
 
Telehealth Expansion for Behavioral Health
The COVID-19 PHE shows gaps in healthcare delivery and the need for technology to treat patients, especially patients located in remote communities. CMS, in this rule, is eliminating barriers and will allow patients to access telehealth services in their homes, for the diagnosis, evaluation, and treatment of mental health disorders.
 
Medicare will also cover mental health visits in Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) through telehealth technologies, including audio only calls.
 
Increasing Access to Physician Assistants’ (PA) Services
CMS will institute a change that will authorize Medicare to make direct Medicare payments to Physician Assistants (PAs) for professional services they furnish under Part B. Beginning January 1, 2022 PAs are permitted to bill Medicare directly. This change allows greater access to care for Medicare beneficiaries. 
 
Medicare Ground Ambulance Data Collection System
CMS finalized changes to the Medicare Ground Ambulance Data Collection System including:
  • Finalizing a new data collection period beginning between January 1, 2023, and December 31, 2023, and a new data reporting period beginning between January 1, 2024, and December 31, 2024, for selected ground ambulance organizations in year three;
  • Revising the timeline for when the payment reduction for failure to report will begin aligning the timelines for the application of penalties for not reporting data; and
  • Amending to the Medicare Ground Ambulance Data Collection Instrument. This will improve its clarity and make the instrument less burdensome to complete.

Click here for the link to the display copy of the Physician Fee Schedule; the document is scheduled to be published in the federal register on 11/19/2021.


 
KEY UPDATES FROM THE CY 2022 HOME HEALTH PPS FINAL RULE:
CY 2022 Home Health Prospective Payment System Rate Update Final Rule (CMS-1747-F & CMS-5531-F)
 
CY 2022 Updates to the Home Health (HH) PPS rates
The final rule updates CY 2022 Medicare Home Health (HH) payment rates by 2.6 percent and uses the latest Core-Based Statistical Area (CBSA) delineations as well as the latest available pre-reclassified hospital wage data under the Medicare IPPS.

CY 2022 Updates to Home Health Quality Reporting Program
The Home Health QRP is a program that reports quality data to CMS. All HHAs that do not meet reporting requirements receive a 2-percentage point reduction to their annual market basket percentage update for the respective calendar year. In this final rule the OASIS-based measure is removed as it did not demonstrate any meaningful difference in performance. Two claim-based measures will be replaced with a new measure that surrounding attribution and associated with desired patient outcomes.
 
CMS is finalizing its proposal that effective January 1, 2023, HHAs begin collecting data on the Transfer of Health Information to Provider-Post Acute Care measure, the Transfer of Health Information to Patient-PAC measure, as well as six categories of standardized patient assessment data elements, to support the coordination of care.
 
Click here for the link to the display copy of the Home Health PPS update; the document is scheduled to be published in the federal register on 11/9/2021

For questions regarding these rules, please contact Scott.Besler@toyonassociates.com.
 
 
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