T-18 Changes: 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 (925) 685-9312 or robert.howey@toyonassociates.com.