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Tag: COVID-19

Transmittal 18 New Cost Reporting Instructions – Section IV. COVID-19 Public Health Emergency Updates 

Transmittal 18 COVID-19 Public Health Emergency Updates include:
 
A. Temporary COVID-19 Beds and Adjustments 
Cost Reports in Effect March 1, 2020 – May 11, 2023 (likely)  
 
Transmittal 18 clarifies the reporting of COVID-19 beds. Providers will report “Temporary Expansion COVID-19 PHE acute care beds” on Worksheet S-3 Part I, new Line 34. This will reduce the bed count on Worksheet E Part A (used for IME reimbursement) by the number of these temporary beds.   
 
Toyon’s take: Additional clarification may be needed defining a temporary expansion COVID-19 PHE acute bed (to be excluded during the PHE, but reported after the PHE expiration). Toyon recommends that providers ensure temporary COVID-19 beds are not, or have not, been reported on Worksheet E part A on cost reports between March 1, 2020 – May 11, 2023 (likely, see below).   
 
B. Subacute Provider Teaching Adjustments 
Cost Reports Beginning After February 29, 2020 and Before May 11, 2023 (likely) 
 
Transmittal 18 includes an update on the determination of the teaching adjustment during certain cost reporting periods. Inpatient Psychiatric Facilities’ (IPF) and Inpatient Rehabilitation Facilities’ (IRF) teaching adjustments will be the higher of the calculated teaching adjustment factor or the teaching adjustment factor for the cost reporting period immediately preceding February 29, 2020. 
 
An Announcement on February 9, 2023 from HHS states that the PHE is planned to expire at the end of the day on May 11, 2023. In this announcement, HHS also states: 
“Certain Medicare and Medicaid waivers and broad flexibilities for health care providers are no longer necessary and will end. During the COVID-19 PHE, CMS has used a combination of emergency authority waivers, regulations, and sub-regulatory guidance to ensure and expand access to care and to give health care providers the flexibilities needed to help keep people safe. States, hospitals, nursing homes, and others are currently operating under hundreds of these waivers that affect care delivery and payment and that are integrated into patient care and provider systems. Many of these waivers and flexibilities were necessary to expand facility capacity for the health care system and to allow the health care system to weather the heightened strain created by COVID-19; given the current state of COVID-19, this excess capacity is no longer necessary.” 
 
Please see CMS’s Hospitals and CAHs (including Swing Beds, DPUs), ASCs and CMHCs: CMS Flexibilities to Fight COVID-19 and CMS COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers that tracks each of the flexibilities that has ended or have ended or will end at the expiration of the PHE. 
 
For further information, please contact Robert Howey at 888.514.9312 or robert.howey@toyonassociates.com
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September 30 Deadline for CARES PRF Reporting Period 3

CARES Provider Relief Fund Reporting Period 3
 
Reminder – providers have until Friday, September 30, to file for Reporting Period 3 (RP3) of the CARES Provider Relief Fund (PRF). Even if $0 PRF was received in RP3, HRSA still requires confirmation (of $0 payments) in the PRF Reporting Portal.   
 
PRF received in RP3 relates to payments (>$10K) received from January 1, 2021 through June 30, 2021.  The period of availability associated with these payments is January 1, 2020 through June 30, 2022. The period of availability reflects COVID-19 expenses and lost revenues that may be used toward recognizing RP3 PRF payments (provided these expenses and lost revenues were not previously used towards PRF in RP1 or RP2). Additional resources for RP3 reporting can be found here on HRSA’s website. 
 
Please contact Fred Fisher at fred.fisher@toyonassociates.com with any questions. 
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CMS Proposes New Cost Reporting Instructions

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.
 
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