J11 Part A Provider Audit and Reimbursement Update

Similar documents
J11 Part A Provider Audit and Reimbursement Update. February 5, 2014

Medicare Update Rural Hospi Rural Hospi al Fi al nance

Uncompensated Care Payments and Worksheet S-10. HFMA Maine Chapter

Wage Index Training NWO HFMA. February 15, 2018

W O R K S H E E T S - 10: K E Y P O I N T S A N D C O N S I D E R AT I O N S F O R C A L C U L AT I N G H O S P I TA L U N C O M P E N S AT E D C A R

Payment Adjustments & Hardship Exceptions for Eligible Hospitals and CAHs Last Updated: March 2014

New IPPS Regulations & Cost Report Forms ( ) Hospital Finance & Reimbursement Workshop Columbia, SC November 15, 2011

Introduction. Incentive Payments for. Health Care Regulatory and Compliance Insights. Daniel F. Gottlieb, Esq.

MU Stage 1 - EP Public Health Reporting Exclusion

NOTE: cost reporting period filed on or before November 15, 2004

Northern California HFMA - Spring Conference. Identification, Documentation, Claiming Medicare Allowable Bad Debts on Your Medicare Cost Report

Form CMS Update Transmittals 20 and 21

Medicare Advantage Reimbursement Issues. Presented by: Jason Johnson John Garcia

FORM CMS This page is reserved for future use Rev. 8

Cost Report Compliance Issues for Critical Access Hospitals

Focusing on the Quadruple Aim

Direct patient care services

Connecticut Medicaid Electronic Health Record Incentive Program

Wisconsin Hospital Association

4012 FORM CMS

ehealth Privacy & Security Interest Group Monthly Call Friday September 26, 2014

DISPROPORTIONATE SHARE HOSPITAL (DSH) PAYMENT EXAMINATION UPDATE DSH YEAR 2013

The Leader in Medicare Cost Report Software. HFS Update. Luke DiSabato Health Financial Systems

Medicare/Medicaid Hospital Reimbursement Update. September 13, 2012

Hospital Cost Report Training Level II Critical Reimbursement Strategies // General Session Dallas - Hilton Dallas/Southlake Town Square

John Hellow Robert Roth Martin Corry

Small Rural Hospital Transition (SRHT) Project Guide

POLK MEDICAL CENTER, INC. ROME, GEORGIA FINANCIAL STATEMENTS. for the years ended June 30, 2016 and 2015

NY HFMA Cost Report Seminar

Form CMS Transmittal 13 Changes

GREENWOOD LEFLORE HOSPITAL. Audited Financial Statements Years Ended September 30, 2015 and 2014

What Medicare Providers Need To Know About the IPPS/OPPS Final Rules and the Bipartisan Budget Act

Helpful Tips on Preparing Your Next Cost Report June 19, 2018

Rochester General Hospital Affiliate Policy & Procedure

RHC Medicare Cost Reporting 101 Katie Jo Raebel, CPA, Partner March 20, 2019

2016 ICR Changes and Filing Procedures. Form CMS Transmittals #7 and #8. Demonstration of Software Enhancements

Tips and Tricks For Understanding Worksheet S-10. Presented By Ellen Donahue, Senior Manager October 3, 2017

DISPROPORTIONATE SHARE HOSPITAL (DSH) PAYMENT EXAMINATION UPDATE DSH YEAR 2014

Current State of Medicare. Robert Roth & John Hellow Hooper, Lundy & Bookman, PC

Current State of Medicare

Additional Documentation Request

Medicare DSH Dissecting Uncompensated Care Cost

Advancing Risk Capability in 2015: Medicare Shared Savings Program and ACO Investment Model. March 23, 2015 // 12:00 P.M. 1:00 P.M.

Reimbursement and Funding Methodology For Demonstration Year 11. Florida s 1115 Managed Medical Assistance Waiver. Low Income Pool

(Cont.) FORM CMS Line For cost reporting periods that overlap October 1, 2013 and subsequent years, enter the amount of the

Maintenance of Personnel. Costed Requisitions. Rev

Billing and Collections Knowledge Assessment

C o s t R e p o r t i n g : M e d i c a r e C o s t R e p o r t M o r e t h a n j u s t C o m p l i a n c e J u l y 1 8,

Medicare Reimbursement Update and Financial Improvement Tools for Rural Hospitals

Baptist Memorial Health Care Corporation and Affiliates

ANMED HEALTH. Financial Statements. 15-month Period Ended December 31, 2012 and the Year Ended September 30, 2011

What Hospitals Need to Know About Cost Report Changes

All the President s Men : Medicare Denials and Appeals

MEDICAID: STATE DISPROPORTIONATE SHARE HOSPITAL ALLOTMENT REDUCTIONS FOR FYs 2014 AND 2015 FINAL RULE SUMMARY. September 17, 2013

Payment Adjustments & Hardship Exceptions Tipsheet for Eligible Professionals Last Updated: August, 2012

Billing and Collections Knowledge Assessment

David S. James, CPA. Advanced RHC Cost Reporting

THE HOSPITAL AUTHORITY OF WAYNE COUNTY, GEORGIA (A Component Unit of Wayne County, Georgia) FINANCIAL STATEMENTS

Financial Statements. Years Ended September 30, 2012 and 2011

Rev. 12 FORM CMS ( ) (INSTRUCTIONS FOR THIS WORKSHEET ARE PUBLISHED IN CMS PUB. 15-2, SECTION )

Cenpatico South Carolina Frequently Asked Questions (FAQ)

Reimbursement & Cost Report Strategies. Reducing cost is NOT always the solution.

(Cont.) FORM CMS Line 4--Enter the amount of outlier payments made for OPPS services rendered during the cost reporting period. C

HFMA s Regulatory Sound Bites. An Overview of the Final 2019 Inpatient Prospective Payment System Rule & Quick look at the Proposed 2019 OPPS

Basic, including 100% Part B coinsurance

Inter-Plan Operations (BlueCard )

Jim Frizzera, Principal Health Management Associates

Helpful Tips for Preventing Claim Delays. An independent licensee of the Blue Cross and Blue Shield Association. U7430a, 2/11

Robert Howey, MBA, MHA, CPA Manager, Medicare Strategy Unit

Basic, including 100% Part B coinsurance

Oklahoma Health Care Authority Oklahoma City, Oklahoma

Cost Reporting 101: Your Medicare Cost Report from A - M

Subtitle B: Incentives for the Use of Health Information Technology SEC. 4311: INCENTIVES FOR ELIGIBLE PROFESSIONALS.

Provider Appeals Submission Best Practices

Emerging Cost Report Issues. Julie Quinn CPA, MBA VP of Cost Reporting & Provider Education Health Services Associates

GREENWOOD LEFLORE HOSPITAL. Audited Financial Statements Years Ended September 30, 2016 and 2015

Reimbursement and Funding Methodology. Florida Medicaid Reform Section 1115 Waiver. Low Income Pool

Rural Health Clinic: Topics in Billing, Cost Reporting & Reimbursement

Gonzales Healthcare Systems Policy

For your convenience, submit this form and any payment due electronically via the eservices portal located at or fax

National Provider Call:

Medicare DSH Update and Recent Developments TAHFA & HFMA Lone Star Chapter West Texas Seminar * Winds of Change * February 13, 2015

Medicare Part A Quarterly Updates. Palmetto GBA JM A/B MAC Provider Outreach & Education September 13, 2017

Medicare Inpatient Prospective Payment System

SELF REGIONAL HEALTHCARE AND AFFILIATES. Combined Financial Statements. September 30, 2013 and ( with Independent Auditors Report thereon )

HFMA FALL MEETING Embassy Suites, Lexington October 23, Stephen P. Miller Vice President of Finance Kentucky Hospital Association

Basic, including 100% Part B coinsurance

Medicare DSH & Worksheet S-10. Kentucky HFMA March 29, 2018

Frequently Asked Questions

Predictive Qualifying Alternative Payment Model (APM) Participants (QPs) Methodology Fact Sheet What is the Predictive QP Status Analysis?

GREENWOOD LEFLORE HOSPITAL. Audited Financial Statements Years Ended September 30, 2017 and 2016

Summary of the Financial Reports for Hospital Corporation of America (HCA)

01/07/2014 Medicare Part D Coverage Gap Discount Program Program Dates Page 1 of 7

2019 Transition Policy

RELIEF FOR ELIGIBLE PROFESSIONALS? PROPOSED STAGE 2 MEANINGFUL USE RULE INCLUDES IMPORTANT (POTENTIAL) EXCEPTIONS [OBER KALER]

Clinical Policies and Procedures for Major Joint and Lower Extremity Services Overview and FAQs for BCBSNC In-Network Providers.

Best Practices for 340B Internal Audits and Key Takeaways from the Winter 340B Coalition Conference

Copyright Scottsdale Institute All Rights Reserved.

WYOMING MEDICAID IMPLEMENTATION OF APR DRGS

North American Healthcare Management Services David S. James, CPA Cost Report Basics

Transcription:

J11 Part A Provider Audit and Reimbursement Update 1

Agenda Operational Update SSI Update Rural Floor Budget Neutrality Adjustment Wage Index 2014 EHR Audits Contacts 2

Operational Update - Audit Columbia, SC SC, NC, HHH Richmond, VA (NGS) VA, WV, NC Springfield, IL No longer J11 Appeals Columbia, SC 3

Operational Update - Reimbursement Columbia, SC All states Rate Reviews Transitioning to a 4 th and 8 th month review period Audit Adjustment Factors Rate Reviews Tentative settlements 4

SSI Update Settlements Staggered settlements Pre-2006 remain on hold 2007 (2006) 2008 2009 2010 (most are in current year workplan) No official CMS guidance 2011+ will continue to be on hold No new documentation 5

SSI Update Settlements 2007 South Carolina 31 Planned settlements 20 Completed 5 Adjustment letters pending 2008 South Carolina 37 Planned settlements 2009 South Carolina 40 Planned settlements 6

SSI Update Reopenings 2006 and 2007 31 2006 SC Reopenings planned 8 2006 SC Completed 10 2007 SC Reopenings planned 0 2007 SC Completed 2008 One reopening planned for Rehab unit Reimbursement Latest published SSI percentages used in rate reviews, tentative settlement 7

RFBN Adjustment Settlement Agreements Amended Cost Reports Acceptance No tentative settlement Reopening Requests Requests for Payment 8

Wage Index 2014 PUF published in October 2012 Missing many 2552-10 files Re-published November 9, 2012 Revision Requests Deadline extended to December 10 Early submission recommended Email account pending 9

Wage Index 2014 Desk reviews start December 10 or sooner Pension Defined Benefit Plan 100% Review CMS Website Development of Pension Costs Desk Reviews completed February 6 Submission of findings to CMS Rebuttal Period ends March 3 Appeal Period ends April 17 10

Wage Index 2014 Pension Plan costs Pension Defined Benefit Plan 100% Review CMS Update Development of Pension Costs 2552-10 Update October 2012 Wage Index Pension Cost Schedule Allowable costs cash basis Average Annual Employer Contributions 36 Consecutive Calendar Months 11

EHR Audits Meaningful Use Audits Audits performed by Figloizzi and Company Audits have started on attestations Audit schedules/details have not been shared with MACs/FIs Payment Audits Audits performed by MACs/FIs CMS to select the sample of providers No timetable to start audits 12

EHR Audits Meaningful Use audit may/may not occur prior to Payment audit Payment Audit Desk Audit Applicable to cost reporting periods of 12 months only Completed at same time as regular desk review or as close to timeframe as possible 13

EHR Audits Payment Audit Audit Field Audit vs. In-House Audit Audit work to be performed in conjunction with regular audit Avoids duplicate work May be instances where the EHR work will be completed separately 14

EHR Audits Payment Audit Desk Review Proper cost reporting Proper transition factors Payment reconciliation Review of 110 and 118 PSR Reports or provider alternative data Pre-scoping of Audit work 15

EHR Audits Payment Audit Audit scope Incentive Payment Calculation provides clues as to areas subject to review IPPS: Initial Amount x Medicare Share x Transition Factor CAH: Reasonable costs of EHR Technology x Medicare Share + 20% (not to exceed 100%) 16

EHR Audits Medicare Share: Inpatient Part A Days + Inpatient Part C Days Total Inpatient Days x ((Total Eligible Charges Charges applicable to Charity Care)/Total Eligible Charges) Expect reviews to focus in part on Medicare Share elements 17

EHR Audits Audit Objectives Verify Medicare Part A and Part C as well as Total Inpatient days Verify hospital charges and charity care charges Verify total discharges (IPPS) Verify reasonable cost of EHR assets (CAH) Ensure costs have not previously been claimed (CAH) 18

EHR Audits Inpatient Days Medicare days: 110 and 118 PSR Reports Total days: Routine and ICU days Census Reports Policies and Procedures Count conforms with hospital policies and procedures Count conforms with Medicare policy * Counted as full days * Day begins at midnight * Day of admission is counted; day of discharge excluded (same day admission/discharge = 1 day) 19

EHR Audits Total Hospital Charges Financials vs. Revenue and Usage Reports Routine Revenue Test 20

EHR Audits Charity Charges W/S S-10 Line 20, Col 3 Reconciliation of charges Listing of charity charges Patient name Dates of service Patient Account Number Name of insurer (private, Medicare, etc.) Total (gross) charges Charity charges 21

EHR Audits Charity Charges Review of charity policies Conforms with PRM I Section 312 Ensure policy is followed Charity charges calculated properly Exclusions: Charges applicable to Medicare patients (ded. and coins. claimed as bad debts and charity care allowances have no relationship to Medicare patients) Courtesy discounts, other discounts Physician and Professional charges 22

EHR Audits Total Discharges (IPPS) Listing of discharges Reconciliation of reported discharges Review of medical records and/or other appropriate documentation to support discharge count 23

EHR Audits Reasonable cost of EHR Assets (CAH) Listing of EHR Assets Identify each asset; notate lease or purchase Tag number/location of each asset Type of use, i.e., will it be shared with non-ehr systems Name of purchaser (hospital, home office, etc.) Date of purchase/virtual lease Acquisition cost 24

EHR Audits Reasonable cost of EHR Assets CAH must support reasonableness of cost Reconciliation of costs Verify costs Invoices, purchase orders Previous purchases; treatment of previously claimed depreciation Physical inspection of assets Interview of staff using assets Exclude interest, previous depreciation and costs that cannot be capitalized (internal training, internally developed software) 25

EHR Audits Reasonable cost of EHR Assets Leased Assets (previously thought to be non-allowable for EHR) Virtual purchase Fair market value (determined by the provider) Excludes cost elements such as depreciation, interest and insurance Assets also used for non-ehr purposes Separately identifiable Reasonableness of allocation methodology (i.e., hours of use) 26

EHR Audits Reasonable cost of EHR Assets Home Office Purchase support for allocations Direct allocation Functional allocation Group purchase Amount claimed must be actual cost incurred by provider 27

EHR Audits Previously incurred costs Plant ledger and depreciation schedules Costs should not be duplicated on depreciation schedules Remove via worksheet A-8, line 32 28

EHR Audits References ARRA of 2009, Pub. L. 111-5 HITECH ACT 42 CFR 413.130, 413.134, 495.104 and 495.106 FR Vol. 75, No. 144 dated 7/28/2010, Pgs. 44448-64 PRM I, 104.1, 104.4, 104.10A, 104.17, 110 and 312 PRM-II, 4004.1, 4005.1, 4012, 4023, 4031.1, 4013, and 4016 CMS Website - FAQs 29

Contact Information Key Contact Information For filing of Cost Reports Courier Service Palmetto GBA Attn: Cost Report Acceptance (AG-330) 2300 Springdale Drive, Building One Camden, SC 29020-1728 U.S. Postal Service Palmetto GBA Attn: Cost Report Acceptance (AG-330) Post Office Box 100144 Columbia, SC 29202-3144 30

Contact Information Key Contact Information HITECH Payment Issues/Hospice Caps Jim Peebles at jim.peebles@palmettogba.com or (803) 382-6118 Courier Service Palmetto GBA Attn: Jim Peebles, Manager (AG-330) 2300 Springdale Drive, Building One Camden, SC 29020-1728 U.S. Postal Service Palmetto GBA Attn: Jim Peebles, Manager (AG-330) Post Office Box 100144 Columbia, SC 29202-3144 31

Contact Information Key Contact Information Reimbursement Issues Michelle Anderson at michelle.anderson@palmettogba.com or (803) 382-6171 Courier Service Palmetto GBA Attn: Michelle Anderson, Supervisor (AG-330) 2300 Springdale Drive, Building One Camden, SC 29020-1728 U.S. Postal Service Palmetto GBA Attn: Michelle Anderson, Supervisor (AG-330) Post Office Box 100144 Columbia, SC 29202-3144 Alternate Contact: Jim Peebles, Manager 32

Contact Information Key Contact Information Provider Audit Issues relating to the cost report, desk reviews, audits, and settlements Palmetto GBA Provider Audit, AG-320 Post Office Box 100144 Columbia SC 29202-3144 Contact: Scott Neely (or assigned manager) Manager, Provider Audit (803) 763-5526 (direct line) (803) 935-0248 (fax) Scott.Neely@palmettogba.com Wage Index email account is pending 33

Contact Information Key Contact Information Provider Audit Filing of Cost Report Appeals and Reopenings Palmetto GBA Cost Report Appeals and Reopenings, AG-380 Post Office Box 100144 Columbia SC 29202-3144 Contact: Cecile Huggins Supervisor, Provider Appeals and Reopenings (803) 382-6242 (direct line) (803) 935-0248 (fax) Cecile.Huggins@palmettogba.com 34

Contact Information Contact Information for Cost Report Appeal and Reopening Requests Two email addresses have been created for the electronic submission of cost report appeals and cost report reopening requests: Filing of Cost Report Appeals CostReport.Appeals@palmettogba.com Filing of Cost Report Reopenings CostReport.Reopening@palmettogba.com 35

Contact Information PRRB appeals correspondence that providers send to the Blue Cross and Blue Shield Association should now be sent via e-mail to ImageNow_SGI@BCBSA.com In the Subject line, reference the case number first, followed by the case name, followed by the nature of the correspondence. For example: Subject: PRRB Case No. 10-9999; ABC Hospital; Provider Preliminary Position Paper There is no need to send a paper copy 36