The Leader in Medicare Cost Report Software HFS Update Luke DiSabato Health Financial Systems
2552-10 TRANSMITTALS 11/12/13 Major Changes Worksheet S-10 clarifications (T-11) Transmittal 12/13 Electronic Signature Effective for cost reporting periods ending on or after 12/31/2017 Revision to LVA Nursing and Allied Health Changes Medicaid Options HIT Changes LTCH Site Neutral Wage Related Costs New Cost Centers Rural Community Hospital Demonstration Program Edit Changes
2552-10 TRANSMITTAL 11 Transmittal 11 contains 3 types of communications Extension for time period to amend previously filed cost reports for FY 2014 and 2015 Worksheet S-10 data changes Data definitions and clarifications for Worksheet S-10 A change impacting the calculation of Uncompensated Care costs
2552-10 TRANSMITTAL 11 Data definitions and clarifications for Worksheet S-10 Line 20 Charity care charges and uninsured discounts Additional items that can be included In addition, enter in column 1 (Uninsured patients), charges for non-covered services provided to patients eligible for Medicaid or other indigent care programs, if such inclusion is specified in the hospital s charity care policy or FAP and the patient meets the hospital s policy criteria. In addition, enter in column 2 (Insured patients), the non-covered charges for days exceeding a length-of-stay limit for patients covered by Medicaid or other indigent care programs if such inclusion is specified in the hospital s charity care policy or FAP and the patient meets the hospital s policy criteria. Line 22 Payments received from patients for amounts previously written off as charity care Clarifications Enter all payments received during this cost reporting period, regardless of when the services were provided, from patients for amounts previously written off on line 20 as charity care or uninsured discounts. Do not include grants or other mechanisms of funding for charity care on line 22. Do not include payments received that represent a patient s liability, or amounts that were not previously written off on line 20 as charity care or uninsured discounts. Line 26 Total bad debts for the entire hospital complex Clarification (Medicare bad debts and non-medicare bad debts), net of recoveries
2552-10 TRANSMITTAL 11 CHANGE IMPACTING THE CALCULATION OF UNCOMPENSATED CARE COSTS Change impacting the calculation of Uncompensated Care costs Line 29 Cost of non-medicare and non-reimbursable Medicare bad debts Previously Non-Medicare bad debt computed as Total bad debt (line 26) Less Medicare reimbursable bad debt (line 27) (bad debts reduced to 65% used) CCR applied to Non-Medicare bad debts T-11 Non-Medicare bad debt computed as Total bed debt (line 26) Less Full Medicare bad debt (line 27.01) (bad debts not reduced to 65% used) Cost of non-medicare and non-reimbursable Medicare bad debts will be calculated as: Non-Medicare bad debts multiplied by CCR, plus Non-reimbursed Medicare bad debts (line 27 27.01) Change reflects full Medicare non-reimbursed bad debts not reduced by CCR
2552-10 TRANSMITTAL 11 CHANGE IMPACTING THE CALCULATION OF UNCOMPENSATED CARE COSTS Change impacting the calculation of Uncompensated Care costs Line 29 Cost of non-medicare and non-reimbursable Medicare bad debts Prior to T-11 Post T-11 Total Facility Previously Bad Debts Non-Medicare bad debt computed as 200,000 200,000 Total bad debt (line 26) Total Reimbursed Medicare Bad Debt 60,024 60,024 Less Medicare reimbursable bad debt (line 27) (bad debts reduced to 65% Total Gross used) Medicare Bad Debt 92,345 92,345 CCR applied to Non-Medicare bad debts Non Medicare Bad Debts 139,976 107,655 T-11 Non-Medicare bad debt computed as Total bed debt (line 26) Less Full Medicare bad debt (line 27.01) (bad debts not reduced to 65% CCR 0.695354 0.695354 used) Cost of non-medicare and non-reimbursable Medicare bad debts will be calculated as: Medicare Non-Reimbursed Bad Debt 32,321 Non-Medicare bad debts multiplied by CCR, plus Non-reimbursed Medicare bad debts (line 27 27.01) Change reflects full Medicare non-reimbursed bad debts not reduced by CCR Bad Debt Costs 97333 107,179
2552-10 TRANSMITTAL 12 Projected to be released November 2017 Published November 17, 2017 Effective for Cost Reporting periods ending on or after August 31, 2017. First major submissions 9/30/2017 FYE Due February 28, 2018 Rescinded by T-13
CMS issued a Transmittal 13 for the hospital cost report, Form CMS- 2552-10. The T-13 reissued all content from T-12 and revised the effective date from cost reporting periods ending on or after August 31, 2017, to cost reporting periods ending on or after September 30, 2017. Any hospital with a fiscal year ending on or after September 30, 2017, should submit using T-13. However, if a hospital with a fiscal year ending on or after September 30, 2017, had already submitted their cost report using T-11, it is not required to resubmit the cost report unless that provider is participating in the Rural Health Demonstration Project and/or has Nursing and Allied Health Education (NAHE) programs. MACs will final settle all fiscal year ending September 30, 2017, on the latest transmittal. HFS Approved 1/31/2018 Software Released 2/8/2018
WORKSHEET S Provision for Electronic Certification Note: not effective until CR Periods ending on or after 12/31/2017
WORKSHEET S Provision for Electronic Certification Note: not effective until CR Periods ending on or after 12/31/2017
EXPIRATION OF TEMPORARY LOW-VOLUME PAYMENT ADJUSTMENT ACA modified LVA for FYs 2011 and 2012 Extended through FY 2017 by MACRA More than 15 miles from another subsection (d) hospital Less than 1,600 Medicare discharges Sliding scale adjustment factor Will revert to previous policy 10/1/2017 More than 25 miles from another subsection (d) hospital Less than 200 discharges (not just Medicare) 25% payment adjustment Will continue cost report reconciliation on Worksheet E, Part A, Exhibit 4
EXPIRATION OF TEMPORARY LOW-VOLUME PAYMENT ADJUSTMENT ACA modified LVA for FYs 2011 and 2012 Extended through FY 2017 by MACRA More than 15 miles from another subsection (d) hospital Less than 1,600 Medicare discharges LVA Sliding Extended scale in Continuing adjustment Resolution factor Continue through FY 2018 Will revert Modify for to FY previous 2019 through policy 202210/1/2017 MDH More also than Extended 25 miles in Continuing from another Resolution subsection through FY (d) 2022 hospital Will Less need than to review 200 discharges implementing (not instructions just Medicare) and Regulations 25% payment adjustment Will continue cost report reconciliation on Worksheet E, Part A, Exhibit 4
WORKSHEET S-2 Low Volume Payment Adjustment Change
NURSING AND ALLIED HEALTH Nursing and Allied Health Worksheet S-2 identify by Program Worksheet A subscript by program Worksheet A-8 offset of tuition by program
NURSING AND ALLIED HEALTH
NURSING AND ALLIED HEALTH Worksheet S-2, Part I
WORKSHEET S-2 Medicaid State provisions Previously HFS provided a Worksheet S-2, Part IX to account for individual State Medicaid provisions. CMS incorporated these questions into the official Worksheet S-2, Part I Effective with T-13 HFS Worksheet S-2, Part IX to be replaced by Worksheet S-2, Part I, lines 98 98.06
WORKSHEET S-2 HFS Worksheet
WORKSHEET S-2 Worksheet S-2, Part I
WORKSHEET S-2 Frontier Community Health Integration Project Aims to develop and test new models of integrated, coordinated health care in the most sparsely-populated rural counties with the goal of improving health outcomes and reducing Medicare expenditures. The Demonstration began August 1, 2016 and is scheduled to run through July 31, 2019. Located in a State where at least 65 percent of the counties have six or fewer residents per square mile; Limited to CAHs in Montana, Nevada, and North Dakota. Identified on Worksheet S-2, Part I, line 111
WORKSHEET S-2
WORKSHEET S-2 HIT Subsection (d) Puerto Rico providers eligible for the electronic health record (EHR) incentive payment for federal fiscal years 2016 through 2021, in accordance with the CCA 2016, Division O, Title VI, 602. Instructions to Worksheet S-2, Part I, line 169 revised accordingly.
WORKSHEET S-2
WORKSHEET S-3 Site neutral days and discharges to be identified on Worksheet S-3, Part I Why? Site neutral days and discharges are not to be used when calculating ALOS. HFS SR903 can be used by MACs/Providers to compute ALOS. Previously Site Neutral info was used from solely PS&R data but now will be reported in cost report.
SR 903
WORKSHEET S-3, PART IV Clarification for Other Wage Related Cost Worksheet S-3, Part IV to be subscripted for each Other wage related costs. 1% test applied to each subscripted and identified Other cost.
WORKSHEET S-3, PART IV Clarification for Other Wage Related Cost Worksheet S-3, Part IV to be subscripted for each Other wage related costs. 1% test applied to each subscipted and identified Other cost.
WORKSHEET A Defined Cost Centers Added Line 77 For services rendered on or after 1/1/2017 Line 93.99 For cost reporting periods ending on or after 9/30/2017
WORKSHEET A Clarification regarding contracted hospice costs Note Requires a revenue offset on Worksheet A-8
WORKSHEET A-8 Nursing and Allied Health Revenue offsets. Dedicated line 19 and subscript for each program:
WORKSHEET B-1 Previously identified issue but one pass through cost center cannot be allocated to an associated sub-line
WORKSHEET D, PARTS III AND IV Worksheets D, Parts III and IV Columns added to identify post step-down adjustments from Worksheet B-2 Previously identified in HFS Only columns
SETTLEMENT WORKSHEETS For all settlement Worksheets CMS has identified pre and post sequestration Demonstration payment adjustments. Worksheet E, Part A example
RURAL COMMUNITY HOSPITAL DEMONSTRATION PROGRAM Qualifications Located in rural area Fewer than 51 beds 24-hour ER care Not designated as CAH Located in States with low population densities Provisions of the 21 st Century Cures Act Extended for an additional 5 years Will solicit additional hospitals Reimbursed at reasonable costs subject to a Target limit
RURAL DEMONSTRATION Previously HFS Worksheet E, Part H, CMS incorporated the Rural Demonstration payment provisions into Worksheet E, Part A and E-2
WORKSHEET E-3, PART IV Effective for cost reporting periods ending on or after 9/30/2017, line 1 will be calculated as the sum of lines 1.01 through 1.04.
EDIT REVISIONS Edit 10450S revised to include Worksheet S-2, Part I, expanded Medicaid data. 9/30/2017 Effective for cost reporting periods ending on or after 9/30/2017
EDIT REVISIONS Edit 10450S also revised to include Worksheet S-2, Part I, expanded line 60 subscripts. Currently T13 shows this effective retroactively, CMS agreed with us to base this on 9-30-17 FYEs
EDIT REVISIONS Edit 10710S added to ensure a free-standing IPF reports Laboratory (line 60) and Drugs charged to patients (line 73) costs. 9/30/2017 Effective for cost reporting periods ending on or after 9/30/2017.
EDIT REVISIONS Edit 12655S added to ensure that if the provider is participating in the Rural Community Hospital Demonstration (line 110) that they do not qualify for traditional DSH (line 22, column 1). Effective for cost reporting periods ending on or after 9/30/2017.
EDIT REVISIONS In T-12 CMS clarified that all Other Wage Related Costs should be separately identified as subscripts of Worksheet S-3, Part IV, line 25. Edit 13225S was added to ensure those separately identified costs total to the costs reported on Worksheet S-3, Part II, line 18. Effective retroactively REVISED CMS has changed this to effective with cost reporting periods ending on or after 9-30-17.
EDIT REVISIONS T-11 added level one edits for Worksheet S-10, CMS clarified in T-12 that S-10 edits only apply to IPPS and CAH providers.
EDIT REVISIONS T-11 clarified that the amount reported on Worksheet S-10, line 20, column 2, should include the charges reported on line 25. Therefore, edit 14006S was added to ensure that any amounts reported on line 25 were also reported on line 20, column 2. Effective for the cost reporting periods beginning in FFY 2014 and later.
EDIT REVISIONS Level one edits for the M series (FQHCs) will only apply if there is Medicare utilization in the FQHC.
EDIT REVISIONS Edit 10160A ensures that if Labor and Delivery room costs are reported on Worksheet A (line 52) then days should be reported on the Worksheet S-3, Part I (line 32) Effective retroactive REVISED CMS has changed this to effective with cost reporting periods ending on or after 9-30-17.
EDIT REVISIONS Edit 10000D was previously a level two edit and ensures that the Medicare and Medicaid outpatient charges (D, Parts V) do not exceed total outpatient charges (Worksheet C). Effective for cost reporting periods ending on or after 9/30/2017.
EDIT REVISIONS T-10 added worksheet E-3, Part III, lines 1.01 1.04 to separately report site neutral and standard LTCH payments. Edit 10180E was added to ensure they add up to the line 1. We are now making line 1 a calculated field with FYE on or after 9-30-17.
2552-10 TRANSMITTAL 11 S-10 EDIT REVISIONS The following edit were added in T-11 to validate the integrity of reported Worksheet S-10 data.
ELECTRONIC SIGNATURES! IPPS Final Rule published in the Federal Register on 8/14/2017 Pages 2025 2026 This final rule allows the provider great flexibility to choose how it wishes to electronically sign the certification statement on the Certification and Settlement Summary page of the Medicare cost report and electronically submit this page. As set forth in section X.A.2. of the preamble of the proposed rule (82 FR 20140), if the provider chooses to sign the certification statement with an electronic signature, this signature must be placed on the signature line of the certification statement and may be (1) any format of the original signature that contains the first and last name of the provider s administrator or chief financial officer (for example, photocopy or stamp) or (2) an electronic signature that must be the first and last name of the provider s administrator or chief financial officer entered in the provider s electronic program. Regardless of which electronic signature method is selected by the provider, to indicate the provider s election to sign the certification statement with an electronic signature, the electronic signature checkbox placed immediately after the certification statement and above the signature line on the Certification and Settlement Summary page of the Medicare cost report must be checked to signify that the certification statement has been read and that an electronic signature will be placed on the signature line by the provider.
ELECTRONIC SIGNATURES! IPPS Final Rule published in the Federal Register on 8/14/2017 Pages 2025 2026 As we stated earlier and in the FY 2018 IPPS/LTCH PPS proposed rule (82 FR 20140), a provider may submit the Certification and Settlement Summary page electronically to the contractor at the same time and in the same manner in which the Medicare cost report is submitted. If the electronic signature is in the format specified (1) or (2) above (and in section X.A.2. of the preamble of the proposed rule), this electronic signature on the Certification and Settlement Summary page of the Medicare cost report can be submitted electronically with the electronic cost report to the provider s contractor. If the provider submits the Medicare cost report file to the contractor via email, the provider may elect to also send the electronically signed certification statement on the Certification and Settlement Summary page to the contractor via the same email or separately in a separate email. In addition, if the certification statement is signed with an electronic signature as in (1) or (2) above (and in section X.A.2. of the preamble of the proposed rule), the Certification and Settlement Summary page of the Medicare cost report can also be submitted on paper to the contractor via regular mailing and would still be considered to have an electronic signature. We will provide further instructions through manual provisions and provider educational materials.
ELECTRONIC SIGNATURES!
ELECTRONIC SIGNATURES! Currently included in 2552-10 T12/T13 and in 216-94 T7. HFS is approved for 2552-10 T12/T13 and is developing the electronic signature process. Targeting this for our 3/9/2018 software update. We still need to work on 216-94 and will let folks know as we progress. We expect as CMS releases other system transmittals we will see these changes in each system and get them to you as soon as possible.
ELECTRONIC SIGNATURES!
ELECTRONIC SIGNATURES! Wet Signature No change in process User will sign report The CFO or Administrator will sign SaFE is optional Extra screen for your information Must sign in to SaFE Extra screen for CFO/Administrator information
ELECTRONIC SIGNATURES! New screens in the HFS EC Export Process.
ELECTRONIC SIGNATURES! Next screen if I will electronically sign the report is selected.
ELECTRONIC SIGNATURES! This is the screen for the information requested when the third option (CFO sign) is chosen.
ELECTRONIC SIGNATURES! This is the screen for the signing package and is only displayed on the CFO signing option.
ELECTRONIC SIGNATURES! This is the screen displayed just before the export begins when the CFO option is chosen. The difference here is that the user cannot specify the location for the ECR and PI files, and they cannot uncheck the option to send to SaFE.
ELECTRONIC SIGNATURES! The HFS Worksheet S, Part II Certification Worksheet
ELECTRONIC SIGNATURES! When the CFO/Administrator will be signing... 1. HFS will e-mail a link to the address you provided. The link will take them to the HFS SaFE site where they can only view the signing package. 2. The signer will be presented with the CMS language and check box. 3. Once the signer signs (checks the box), the user/preparer will be notified by e-mail that the report has been signed. 4. The signer and the user/preparer will have the necessary files to submit.
ELECTRONIC SIGNATURES! As we release the new signing ability, HFS will follow up with more information regarding the process. If you have any questions or concern do not hesitate to let us know. Becky Dolin 916.226.6269 Becky.Dolin@hfssoft.com Support@hfssoft.com