Last week, CHA sent a letter to the Centers for Medicare & Medicaid Services (CMS) outlining concerns about the use of Worksheet S-10 data in the Medicare uncompensated care (UCC) payment distribution methodology. CHA urged CMS to delay the current deadline for cost report audits.
CHA believes that if CMS proceeds with expected plans, Medicare UCC payments from hospitals that have undergone Worksheet S-10 reviews could be redistributed to those that have not; these redistributions could be substantial. Such an inappropriate redistribution would significantly impact many providers’ financial viability and, therefore, threatens Medicare beneficiaries’ ability to access care.
In the letter, CHA urged CMS to:
- Rescind guidance that has been issued to the Medicare administrative contractors (MACs) and their subcontractors related to current adjustments to Line 22 on federal fiscal year (FFY) 2015 Worksheet S-10; this guidance reflects an inappropriate interpretation of expected versus actual payments received.
- Delay the current Jan. 31 deadline for MACs to submit the amended cost report data reflecting these and other adjustments. This delay would allow time for correction so that the file used for FFY 2020 rulemaking is not compromised.
- Fully address, through notice and comment rulemaking, the significant policy issues that these reviews have uncovered and their implications for FFY 2020 Medicare UCC payments so that stakeholders can provide substantive analysis and thoughtful comments to help guide the agency’s next steps.
For the past several months, CHA has convened providers, cost report experts and Noridian (California’s MAC) in an effort to proactively identify key reporting issues that remain unaddressed by the agency. CHA thanks members for their invaluable feedback, which helped inform the letter.