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LATEST INDUSTRY NEWS

CMS Publishes Federal Fiscal Year 2020 SSI Ratios

In late February, CMS issued the Federal Fiscal Year (FFY) 2020 acute care SSI ratios. The FFY 2020 SSI ratios are used for the computation of provider FFY 2020 empirical DSH payments (cost reporting period beginning between 10/1/2019 – 9/30/2020). CMS has not yet released the FFY 2020 Low-Income Patient (LIP) SSI ratios for Inpatient Rehabilitation Facilities.  We expect CMS to issue LIP SSI ratios soon.
 
Acute SSI ratios: DSH Adjustment and 2019-2020 File (ZIP)
Upon issuance, LIP SSI ratios can be located at: https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/InpatientRehabFacPPS/SSIData
 
Medicare DSH Providers in the Ninth Circuit
Similar to FFY 2019,  the FFY 2020 SSI ratios include only “covered” SSI days (as opposed to “eligible” SSI days) for providers in the Ninth Circuit per Empire Health Foundation v. Azar. (“the Empire Case”). The Ninth Circuit decision impacts the SSI ratios for providers in Alaska, Arizona, California, Hawaii, Idaho, Montana, Nevada, Oregon, and Washington. The availability of FFY 2020 SSI ratios allow providers, including those in the Ninth Circuit, to preliminarily settle cost reports related to FFY 2020. The Empire Case is currently pending before the Supreme Court. 
 
All other Medicare DSH Providers
All other DSH hospitals outside of the Ninth Circuit have FFY 2020 SSI ratios consistent with existing CMS regulations (using “eligible” SSI days, as opposed to “covered” SSI days). Although CMS states the FFY 2020 SSI ratios are preliminary, Toyon recommends DSH providers appeal any FFY 2020 cost report whereby an NPR is issued prior to the Supreme Court decision on the Empire Case.  
 
Please feel free to contact Dylan Chinea at 925.685.9312, ext. 3121, dylan.chinea@toyonassociates.com with any questions. 
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Upcoming Deadline: Applications for New Medical Education Slots Due March 31, 2022

Hospitals have until March 31, 2022 to apply for up to five new FTE cap slots for distribution in FFY 2023.  Further instructions and the application for FTE cap slots is available on the CMS Graduate Medical Education website.
 
Background
CMS finalized rules on the distribution of 1,000 new resident FTE cap slots over five years (200 per year) under Section 126 of the Consolidated Appropriations Act, 2021 (CAA) for hospitals looking to establish or expand residency programs. The additional cap slots will be distributed to hospitals that are included in the following four categories (with at least 10% of slots going to each category): 
  1. Hospitals located in rural areas or that are treated as being in a rural area.
  2. Hospitals that are training residents over their cap amount.
  3. Hospitals located in the 35 states (listed in the CAA) with new medical schools or additional locations and branches of existing campuses.
  4. Hospitals that train residents in a program where at least 50 percent of the residents’ training time occurs at site(s) physically located in (a) geographic Health Professional Shortage Area(s) (HPSA).
 
HPSA scores will be a key criterion for all four categories, not just category four. Hospitals can find information about the HPSA or HPSAs associated with their training program locations using HRSA’s Search Tool.  CMS will prioritize applications by descending HPSA score. When hospitals have the same HPSA score[1], applications are next prioritized for hospitals with fewer than 250 beds. 
 
The next medical education deadline associated with Section 131 of the CAA is July 1, 2022 for hospitals looking to reset their PRAs and/or FTE resident caps (providers with fewer than 1.0 FTE in a cost reporting period beginning before October 1, 1997; or fewer than 3.0 FTEs in a cost reporting period beginning on or after October 1, 1997 and before December 27, 2020). The 7/1/2022 deadline is only for hospitals that believe the published HCRIS data is not accurate, and who want to provide documentation to challenge it. For more information, please see Toyon’s News You Need to Know article here from January 7, 2022. 
 
Please contact Tom Hubner with questions at 888.514.9312, or tom.hubner@toyonassociates.com.
 
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[1] CMS is seeking comment on the dependence of geographic HPSA residents on health services provided outside of their HPSA, and a feasible alternative for potential use in future rulemaking.
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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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