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FFY 2019 Uncompensated Care Payments to Come From 2014, 2015 Worksheet S-10 Data: Worksheet S-10 audits have begun for select hospitals (September 2018)

S-10 Audit Letters

CHA Executive Briefing (October 16, 2017)

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The Centers for Medicare & Medicaid Services (CMS) has updated its instructions for Worksheet S-10. The update, attached, clarifies definitions and instructions for uncompensated care, non-Medicare bad debt, non-reimbursed Medicare bad debt and charity care to include uninsured discounts. It also modifies the calculation relative to uncompensated care costs. The changes are effective for cost reporting years from Oct. 1, 2013, onward. CHA is currently reviewing the revisions and will provide members with more detail in the coming weeks.

In addition, CMS has extended the deadline for hospitals to revise and submit amended cost reports for federal fiscal years (FFY) 2014 and 2015 from Sept. 30 to Oct. 31. CHA urges members to review Worksheet S-10 of their FFY 2014 and 2015 cost reports and submit amendments to their respective Medicare administrative contractors before the Oct. 31 deadline. More information is available in the attached MLN Matters article. 

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On Sept. 27, CHA submitted the attached comments on the Enhancements of the Overall Hospital Quality Star Ratings report, which proposed improvements to the overall star rating methodology.

In the letter, CHA urges CMS to remove the hospital star ratings until all comments are responded to and errors are addressed. CHA also shares concerns about CMS using the contractor who developed and implemented the five star methodology to also conduct the evaluation of it.

CHA strongly supports alternative approaches to an overall five star rating, as well as the proposal to remove hospitals that do not meet the public reporting thresholds for measures from its k-means clustering analysis, which adversely affects the star ratings categories.  

CHA also supports CMS’ proposal to run the k-means clustering analysis to convergence, ensuring that each observation within a cluster is more similar to the other observations within that cluster than to observations in the other clusters.

CHA is pleased that CMS has announced it is postponing the October 2017 update of its Overall Hospital Quality Star Ratings as it continues to examine potential changes to the methodology based on public feedback. While data from the October Star Ratings Preview Reports will not be published on Hospital Compare, Star Ratings released in December 2016 will remain on the site until the next update.

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The Centers for Medicare & Medicaid Services (CMS) has issued the attached request for information seeking stakeholder input on potential new models that could be tested by its Center for Medicare & Medicaid Innovation (CMMI). Specifically, CMS seeks input on a new direction for CMMI to promote patient-centered care and test market-driven reforms that empower beneficiaries as consumers, provide price transparency, increase choices and competition to drive quality, reduce costs and improve outcomes.

CMS provides information on eight areas it is interested in testing new models for: increased participation in advanced alternative payment models; consumer-directed care and market-based innovation models; physician specialty models; prescription drug models; Medicare Advantage innovation models; state-based and local innovation, including Medicaid-focused models; mental and behavioral health models; and program integrity. Comments can be submitted online or via email to CMMI_NewDirection@cms.hhs.gov by 8:59 p.m. (PT) on Nov. 20.

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CHA has released the attached summary, prepared by Health Policy Alternatives, on the Centers for Medicare & Medicaid Services’ (CMS) proposed rule that would cancel the episode payment models (EPMs) and the cardiac rehabilitation incentive payment model scheduled to begin Jan. 1, 2018. 

The rule also proposes to revise aspects of the ongoing Comprehensive Care for Joint Replacement (CJR) model involving mandatory hospital participation, Track 1 clinician eligibility, reconciliation calculation and telehealth service payment.

CMS proposes to reduce the number of mandatory metropolitan statistical areas (MSAs) to include 34 continued mandatory MSAs and 33 voluntary (formerly mandatory) participation MSAs, including two in California: Modesto and San Francisco-Oakland-Hayward. The Los Angeles-Long Beach-Anaheim MSA remains on CMS’ list for mandatory participation.

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The Centers for Medicare & Medicaid Services’ (CMS’) federal fiscal year (FFY) 2018 inpatient prospective payment system final rule establishes changes to fund distribution for Medicare disproportionate share hospital (DSH) uncompensated care (UCC) payments. CMS determined that it will phase-in payments based on information collected from Line 30 on the S-10 Worksheet of the Medicare cost report to determine the UCC payment factor, starting with FFY 2014 cost reports for DSH UCC payments in FFY 2018.

As previously reported in CHA News, hospitals may submit revisions to Worksheet S-10 of their Medicare cost report for FFYs 2014 and 2015. CHA urges members to review Worksheet S-10 of their FFY 2014 and 2015 cost reports and submit amendments to their respective Medicare administrative contractors before the Oct. 31 deadline.

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The Centers for Medicare & Medicaid Services (CMS) has issued the attached proposed rule that would cancel the episode payment models (EPMs) and the cardiac rehabilitation incentive payment model, scheduled to begin Jan. 1, 2018. The proposed rule would also reduce the number of mandatory metropolitan statistical areas (MSAs) participating in the Comprehensive Care for Joint Replacement (CJR) model, including two in California: Modesto and San Francisco-Oakland-Hayward. Los Angeles-Long Beach-Anaheim remains on CMS’ list of MSAs for mandatory participation.

In addition, CMS proposes to exempt rural hospitals and low-volume hospitals located in the mandatory participation MSAs from required participation in the CJR model beginning in February 2018, and allow them instead to make a one-time voluntary participation election.