Tag: Medicaid DSH

• Patients with a pending positive test that came back positive after June 10 are not allowed in COVID-19 admissions data due June 15.
• Do not include emergency department patients in COVID-19 admissions data.
• Admissions occurring at multiple campuses, under the same TIN, should be reported separately and not rolled up into one count.
• If the prior submission of COVID-19 positive admissions was submitted in error (i.e., all COVID-19 positive admissions submitted by system instead of by facility), HHS requests providers to use TeleTracking to correct and update the data to reflect all COVID-19 positive inpatient admissions from January 1 through June 10.

• HHS expects providers will only use Provider Relief Fund payments for permissible purposes. If, at the conclusion of the pandemic, providers have leftover Provider Relief Fund money that cannot be expended on permissible expenses or losses, then providers will return this money to HHS. 

• HHS will be providing further guidance about the type of documentation to provide per the terms and conditions (e.g., documentation due with quarterly reports July 10).  
• HHS clarifies the term “healthcare related expenses attributable to coronavirus” is a broad term for determining eligibility of expenses and lost revenues eligible for reimbursement including:
  • supplies used to provide healthcare services for possible or actual COVID-19 patients,
  • equipment used to provide healthcare services for possible or actual COVID-19 patients,
  • workforce training; developing and staffing emergency operation centers; reporting COVID-19 test results to federal, state, or local governments,
  • building or constructing temporary structures to expand capacity for COVID-19 patient care or to provide healthcare services to non-COVID-19 patients in a separate area from where COVID-19 patients are being treated; and
  • acquiring additional resources, including facilities, equipment, supplies, healthcare practices, staffing, and technology to expand or preserve care delivery.
• Providers may have incurred eligible health care related expenses attributable to coronavirus prior to the date on which they received their payment.  HHS expects that it would be highly unusual for providers to have incurred eligible expenses prior to January 1.
• The term “lost revenues that are attributable to coronavirus” means any revenue lost to providers due to the coronavirus. 
• HHS encourages the use of funds to cover lost revenue so providers can respond to the coronavirus public health emergency to cover employee or contractor payroll, employee health insurance, rent or mortgage payments, equipment lease payments and electronic health record licensing fees.

• Parent organizations with multiple billing TINs that each received payments, may attest and keep the payments as long as providers associated with the parent organization were providing diagnoses, testing, or care for individuals with possible or actual cases of COVID-19 on or after January 31 and can otherwise attest to the Terms and Conditions.  The parent organization can allocate funds at its discretion to its subsidiaries. If the parent organization would like to control and allocate Provider Relief Fund payments to its subsidiaries, the parent organization must attest to accepting its subsidiaries’ payments and agreeing to the Terms and Conditions.
• Providers with TINs covering all business lines can report lost revenues under the same TIN that are actively caring for patients with COVID-19 or actively working to prevent the spread of COVID-19.
• Parent entities, submitting revenue information on behalf their subsidiaries may encounter an issue if they have multiple Medicare/Medicaid provider numbers (there is only one space in the HHS Portals to populate these numbers). HHS states these providers should submit a statement on the first page of the uploaded tax return file stating (i) the parent entity’s Filing TIN and that it does not bill Medicare and (ii) a schedule of the billing subsidiaries, their Billing TINs, their Medicare/Medicaid ID numbers, and gross sales or receipts.

• $15 billion Medicaid and CHIP funding to eligible providers that participate in state programs and have not received a payment from the Provider Relief Fund General Distribution. Approximately one million health care providers may be eligible for this funding.
• $10 billion safety net funding to approximately 760 hospitals. HHS states the safety net distribution will occur this week. Recipients will receive a minimum payment of $5 million and a maximum payment of $50 million. In order to qualify for this funding, hospitals must have:
  • A Medicare Disproportionate Payment Percentage (DPP) of 20.2 percent or greater,
  • average Uncompensated Care per bed of $25,000 or more, and
  • profitability of 3 percent or less, as reported to CMS in its most recently filed Cost Report.

From: Federal Register – CMS-2315-F – 12/3/14

CMS released a final rule that addresses the hospital-specific limitation on Medicaid disproportionate share hospital (DSH) payments.  Under this limitation, DSH payments to a hospital cannot exceed the uncompensated costs of furnishing hospital services by the hospital to individuals who are Medicaid-eligible or “have no health insurance.  The changes in definitions could be troublesome for California’s Designated Public Hospitals and are cause for concern

I have included AHA’s summary below that has a favorable take on CMS’s issuance:

The Centers for Medicare & Medicaid Services (CMS) on Nov. 28 issued a long-awaited final rule to define “uninsured” for purposes of calculating the Medicaid hospital-specific Disproportionate Share Hospital (DSH) payment limit. The final rule takes effect Dec. 31. In addition, on Nov. 28, the Department of Health and Human Services (HHS) released a notice with the Medicaid and Children’s Health Insurance Program federal medical assistance percentages (FMAP) for fiscal year (FY) 2016.

Highlights of the rule and notice follow.

CMS MEDICAID DSH DEFINITION FINAL RULE: The final rule is effective for DSH audits and reports submitted for state plan rate year (SPRY) 2011 and after. All states are required to submit their 2011 SPRY audit report to CMS by Dec. 31. The rule amends the definition of “uninsured” for purposes of calculating the hospital-specific DSH payment limit, which is tied to a hospital’s Medicaid payment shortfall plus uncompensated care costs. Previously, CMS applied a more restrictive definition for uninsured. AHA advocated for CMS to provide greater flexibility in the definition of uninsured costs. The amended definition expands the inclusion of the following costs for purposes of calculating the DSH limit.

• The cost of inpatient and outpatient hospital services furnished to a Medicaid patient who has exhausted applicable state coverage limits can be included in calculating the Medicaid shortfall.
• The cost of hospital services for individuals who exhausted their insurance benefits or reached lifetime insurance limits can be counted as uninsured costs. These include costs for services not included in the individual’s benefit package, but identified as covered benefits in the state Medicaid plan.
• The costs of inpatient and outpatient hospital services provided to individuals covered under the Indian Health Services (IHS) can be counted as uninsured costs if the services are provided by a non-IHS hospital and not through an IHS health services contract.

The final rule reiterates previous CMS policy that certain costs are not allowed to be counted for purposes of calculating the DSH limit. Those “unallowable” costs include: bad debt, unpaid coinsurance and deductibles, and hospital-based physician costs.

CMS will provide further guidance to states, auditors and providers, and it has instructed Medicaid DSH auditors to apply the new policy to the DSH audits for SPRY 2011.

HHS NOTICE REGARDING FY 2016 FMAPS: The notice provides the state-by-state FMAP percentages for Medicaid, Children’s Health Insurance Program and disaster-recovery FMAP adjustments. The FMAPs are effective Oct. 1, 2015.

Medicaid Program; Disproportionate Share Hospital Payments—Uninsured Definition – Final Rule