MCR Forms Changes

October 11, 2018 Presented by Eric Swanson

Overview

• Agenda • 2019 IPPS Final Rule • Transmittal Changes • Questions

10/1/2018 2 FFY 2019 IPPS PROPOSED RULE

10/1/2018 3

FFY 2019 IPPS FINAL RULE

• Supporting documents: • Teaching hospitals‐‐For teaching hospitals, the Intern and Resident Information System (IRIS) data. • Bad debt‐‐Effective for cost reporting periods beginning on or after October 1, 2018, for providers claiming Medicare bad debt reimbursement, a detailed bad debt listing that corresponds to the amount of bad debt claimed in the provider’s cost report. • DSH eligible hospitals‐‐Effective for cost reporting periods beginning on or after October 1, 2018, for hospitals claiming a disproportionate share hospital payment adjustment, a detailed listing of the hospital’s Medicaid eligible days that corresponds to the Medicaid eligible days claimed in the hospital’s cost report. If the hospital submits an amended cost report that changes its Medicaid eligible days, the hospital must submit an amended listing or an addendum to the original listing of the hospital’s Medicaid eligible days that corresponds to the Medicaid eligible days claimed in the hospital’s amended cost report. • Charity care and uninsured discounts‐‐Effective for cost reporting periods beginning on or after October 1, 2018, for DSH eligible hospitals reporting charity care and/or uninsured discounts, a detailed listing of charity care and/or uninsured discounts that corresponds to the amounts claimed in the DSH eligible hospital’s cost report. • Home Office (Next Slide).

10/1/2018 4 FFY 2019 IPPS FINAL RULE

• Supporting documents: • Home office cost allocation. 1. Same fiscal year end. Effective for cost reporting periods beginning on or after October 1, 2018, for providers claiming costs on their cost report that are allocated from a home office or chain organization with the same fiscal year end, a Home Office Cost Statement completed and submitted by the home office or chain organization to its chain provider’s servicing contractor that corresponds to the amounts allocated from the home office or chain organization to the provider’s cost report. 2. Differing fiscal year end. Effective for cost reporting periods beginning on or after October 1, 2018, for providers claiming costs on their cost report that are allocated from a home office or chain organization with a different fiscal year end, a Home Office Cost Statement completed and submitted by the home office or chain organization to its chain provider’s servicing contractor that corresponds to some portion of the amounts allocated from the home office or chain organization to the provider’s cost report.

10/1/2018 5

Transmittal Updates

Form Type Latest CMS HFS HFS Effective Transmittal Issued Approved Released Date 2552‐10 Hospital 14 3/16/2018 4/6/2018 4/13/2018 2540‐10 SNF 8 3/9/2018 3/29/2018 4/6/2018 216‐94 OPO 7 10/6/2017 3/29/2018 4/16/2018 1728‐94 HHA 18 3/16/2018 4/6/2018 4/13/2018 265‐11 ESRD 4 2/16/2018 4/6/2018 4/13/2018 224‐14 FQHC 4 3/9/2018 4/17/2018 4/17/2018 1984‐14 Hospice 3 4/13/2018 4/20/2018 4/26/2018 Recent Publications 222‐17 RHC 1 5/18/2018 9/7/2018 10/26/2018 Ending on or after 9/30/2018 2088‐17 CMHC 1 5/18/2018 8/24/2018 10/26/2018 Ending on or after 9/30/2018 No Recent Changes 287‐05 HO 10/1/2018 6 2552‐10 T‐14

• Hospital Transmittal 14 • CMS issued Transmittal 14 on March 16, 2018 • HFS was approved by CMS for Transmittal 14 on April 6, 2018 • HFS released Transmittal 14 on April 13, 2018 • Effective Date ‐ Cost Reporting Periods Ending on or After January 31, 2017

This transmittal updates Chapter 40, Hospital and Hospital Health Care Complex Cost Report (Form CMS‐2552‐10), by accommodating select provisions of the Bipartisan Budget Act of 2018, and the Fiscal Year (FY) 2018 Inpatient Prospective Payment System (IPPS) and Long Term Care Hospital (LTCH) PPS Final Rule. This transmittal also updates Chapter 40 by clarifying and correcting the existing instructions as well as incorporating additional statutory and regulatory changes.

10/1/2018 7

2552‐10 T‐14 (Specific Changes).

• Worksheet S‐2, Part I: • Modified the instructions for Worksheet S‐2, Part I, line 39 to reflect the extension of the inpatient hospital adjustment for low‐volume hospitals for discharges occurring through FY 2018.

10/1/2018 8 Adjustment for Low Volume Hospitals

• Section 50204 of the Bipartisan Budget Act of 2018 Modified LVA • For FY 2018 Extended • More than 15 miles from another subsection (d) hospital • Less than 1,600 Medicare discharges • Sliding scale adjustment factor • For FY 2019 – 2022 • More than 15 miles from another subsection (d) hospital • Less than 3,800 Total discharges • Based on most recently submitted cost report • Sliding scale adjustment factor • 25% for 500 or fewer • For FY 2023 reverts to pre FY 2011

10/1/2018 9

2552‐10 T‐14 (Specific Changes).

• Worksheet S‐2, Part I: • Clarified the instructions for Worksheet S‐2, Part I, lines 61 – 61.06 as the ACA section 5503 evaluation period requirements expired July 1, 2016.

10/1/2018 10 2552‐10 T‐14 (Specific Changes).

• Worksheet S‐3, Part I: • Opened Worksheet S‐3, Part I, line 33, column 13 for the reporting of discharges associated with non‐covered LTCH Medicare days.

10/1/2018 11

2552‐10 T‐14 (Specific Changes).

• Worksheet S‐10: • Clarified the instructions for Worksheet S‐10 lines 28 and 29.

10/1/2018 12 2552‐10 T‐14 (Specific Changes).

• Worksheet E, Part A: • Clarified the instruction for Worksheet E, Part A, line 8.01 as the ACA section 5503 evaluation period requirements expired July 1, 2016. • Updated the instructions to Worksheet E, Part A, lines 48 and 49 to reflect the extension of the Medicare‐ dependent hospital (MDH) program through September 30, 2022, in accordance with the Bipartisan Budget Act of 2018, §50205.

10/1/2018 13

2552‐10 T‐14 (Specific Changes).

• Worksheet E‐4: • Clarified the instruction for Worksheet E‐4, line 4.01 as the ACA section 5503 evaluation period requirements expired July 1, 2016.

10/1/2018 14 2552‐10 T‐14 (Specific Changes).

• Worksheet O and O‐1 ‐ O‐4: • Added a line 42.50 to report the costs of drugs furnished to individual patients.

10/1/2018 15

2552‐10 T‐14 (Specific Changes).

• New Edits • If Worksheet S‐2, Part I, line 60, column 1=“Y”, then line 60.01 and subscripts, columns 2 and 3, must be present. [09/30/2017]

10/1/2018 16 2552‐10 T‐14 (Specific Changes).

• New Edits • 10710S If the CCN on Worksheet S‐2, Part, I, column 2, line 3, is XX‐4000 through XX‐4499 (freestanding IPF), then Worksheet B, Part I, column 26, lines 60 and 73, must be greater than zero. [09/30/2017] • Required separate reporting of LAB and Drugs Charged to Patients for IPF providers • Was hitting many all‐inclusive rate State IPF facilities • Bringing back for FYE on or after 8/31/2018 excluding all‐ inclusive rate providers.

10/1/2018 17

2552‐10 T‐14 (Specific Changes).

• New Edits • 14005S Worksheet S‐10, line 20, column 3, must be less than Worksheet C, line 200, column 8. If Worksheet S‐2, Part I, line 115, column 1, is “Y”, do not apply this edit. [10/01/2013b] Edit created issues for all‐inclusive providers.

10/1/2018 18 2552‐10 T‐14 (Specific Changes).

• Clarified Edits • 14006S Worksheet S‐10, line 20, column 2, must be greater than or equal to line 25. [10/01/2013b] • 14015S If Worksheet S‐10, line 27.01, is greater than zero, then line 26 must be greater than or equal to line 27.01, and line 27 must be less than 27.01. [10/01/2013b]

10/1/2018 19

2552‐10 T‐14 (Specific Changes).

• Revised Edits • 10540D Worksheet D‐5, column 1, may only contain Worksheet A line numbers 4 through 41, 43, 50 through 77, 90 through 99, 105 through 111, 115, and subscripts as allowed. [05/01/2010b] • Used to apply to A‐8‐2, now will only apply to Worksheet D‐5 (Apportionment of Costs for Physicians’ Services in a Teaching Hospital)

10/1/2018 20 2552‐10 T‐14 (Specific Changes).

• New Edits • 10830E If Worksheet E‐4, line 6, or line 8, column 3, is greater than zero, then both lines must be greater than zero, and line 8, column 3, must be less than or equal to line 6. [01/31/2018]

10/1/2018 21

2540‐10 T8

• SNF Transmittal 8 • CMS issued Transmittal 8 on March 9, 2018 • HFS was approved by CMS for Transmittal 8 on March 29, 2018 • HFS released Transmittal 8 on April 6, 2018 • Effective Date ‐ Cost Reporting Periods Ending on or After December 31, 2017 • The primary purpose of Transmittal 8 was the incorporation of a Worksheet S, Part II, check box to the certification and settlement summary statement for electronic signature submission to the Skilled Nursing Facility cost reporting forms. This provision is available as an option for cost reporting periods ending on or after 12/31/2017 in accordance with 42 CFR 413.24(f)(4)(iv).

10/1/2018 22 2540‐10 T8 (continued)

• Worksheet S • Part I –No Utilization • CMS added Worksheet S, Part I, line 3.01 to accommodate the reporting of a No Utilization Cost Report • The MAC may verify

10/1/2018 23

2540‐10 T8 (continued)

• Worksheet S‐2, Part I • Line 19 Low Utilization • Requires prior approval • The MAC may verify

10/1/2018 24 2540‐10 T8 (continued)

• Worksheet S • Part II modified for Electronic Signature

10/1/2018 25

2540‐10 T8 (continued)

• New Edits • Wage Index Data Accuracy 1115S All amounts on Worksheet S‐3, Part II and III, column 3, must be equal to or greater than zero. [10/01/2015b]

• If you have RUGs you must have charges

1215S If Worksheet S‐7, line 100, column 2 is greater than zero then Worksheet D, Part 1, line 100, column 2 must also be greater than zero. [06/01/2018]

10/1/2018 26 2540‐10 T8 (continued)

• New Edits • Multiple SNF‐Based Hospice edits added that will be new for 12/31/2017 cost report for data accuracy

1300S If Worksheet S‐8, line 10, column 4, is greater than zero then Worksheet O‐1, line 100, column 7, must be greater than zero and vice versa. [09/30/16]

1310S If Worksheet S‐8, line 11, column 4, is greater than zero then Worksheet O‐2, line 100, column 7, must be greater than zero and vice versa. [09/30/16]

1320S If Worksheet S‐8, line 12, column 4, is greater than zero then Worksheet O‐3, line 100, column 7, must be greater than zero and vice versa. [09/30/16]

1330S If Worksheet S‐8, line 13, column 4, is greater than zero then Worksheet O‐4, line 100, column 7, must be greater than zero and vice versa. [09/30/16]

10/1/2018 27

216‐94 Transmittal 7

• OPO Transmittal 7 • CMS issued Transmittal 7 on October 6, 2017 • HFS was approved by CMS for Transmittal 7 on March 29, 2018 • HFS released Transmittal 7 on April 16 2018 • Effective Date ‐ Cost Reporting Periods Ending on or After December 31, 2017 • Changes include: • The primary change in Transmittal 7 was the incorporation of a Worksheet S, check box to the certification and settlement summary statement for electronic signature submission to the Organ Procurement Organization cost reporting forms. This provision is available as an option for cost reporting periods ending on or after 12/31/2017 in accordance with 42 CFR 413.24(f)(4)(iv). • This transmittal also included instructional clarifications regarding the reporting of “en bloc” organs.

10/1/2018 28 216‐94 Transmittal 7

• OPO Transmittal 7 • Worksheet S, Part I • Added cost report status data consistent with other forms

10/1/2018 29

216‐94 Transmittal 7

• OPO Transmittal 7 • Worksheet S, Part II • Revised for Electronic Signature

10/1/2018 30 216‐94 Transmittal 7

• OPO Transmittal 7

10/1/2018 31

1728‐94 Transmittal 18

• HHA Transmittal 18 • CMS issued Transmittal 18 on March 16, 2018 • HFS was approved by CMS for Transmittal 18 on April 6, 2018 • HFS released Transmittal 18 on April 13, 2018 • Effective Date ‐ Cost Reporting Periods Ending on or After December 31, 2017

The primary change in Transmittal 18 was the incorporation of a Worksheet S, check box to the certification and settlement summary statement for electronic signature submission to the Home Health Agency cost reporting forms. This provision is available as an option for cost reporting periods ending on or after 12/31/2017 in accordance with 42 CFR 413.24(f)(4)(iv).

10/1/2018 32 1728‐94 Transmittal 18

• Other Changes • Worksheet S, Part I

10/1/2018 33

1728‐94 Transmittal 18

• New Edits • Effective for cost reporting periods beginning on or after 10/01/2015 to review accuracy of Worksheet S‐2‐1 (339 Questions) • 1050S ‐ For Worksheet S‐2‐1, there must be a “Y” or “N” response on lines 1 through 6, 9, 10, and 14, column 1. If column 1, line 6, is “Y”, then column 1, lines 7 and 8, must be “Y” or “N”. If column 1, line 6 is “N”, then column 1 lines 7 and 8 must be blank. If column 1, lines 9 or 10, is “Y”, then column 1, lines 11, 12, and 13, must be “Y” or “N”. If both lines 9 and 10, column 1 are “N”, then lines 11, 12, and 13, column 1 must be blank. [10/01/2015b]

10/1/2018 34 1728‐94 Transmittal 18

• New Edits • 1051S ‐ If Worksheet S‐2‐1, column 1, line 3, is “N”, then Worksheet A‐6 must not be present. [10/01/2015b] • 1052S ‐ If Worksheet S‐2‐1, column 1, line 3 is “Y”, then Worksheet A‐6, Part B, columns 4 or 5, sum of lines 1 through 3, must not equal zero, and Worksheet A‐6, Part C, column 1, any one of lines 1 through 5, must contain one of the alpha characters A, B, C, D, E, F, or G. [10/01/2015b]

10/1/2018 35

1728‐94 Transmittal 18

• New Edits • 1053S ‐ For Worksheet S‐2‐1, if column 1, line 4, is ”Y”, then column 2 must contain an “A”, “C”, or “R” response and column 3, if entered, must contain a valid date (MM/DD/YYYY). If Worksheet S‐2‐1, column 1, line 4 is “N”, then columns 2 and 3 must be blank. [10/01/2015b]

10/1/2018 36 1728‐94 Transmittal 18

• New Edits • 1055S ‐ For Worksheet S‐2‐1, if the response on lines 1, 9, or 10, column 1 is “Y”, a valid date (MM/DD/YYYY) must be entered in column 2 for the corresponding line, and vice versa. If the response on line 2, column 1 is “Y”, a valid date (MM/DD/YYYY) must be entered in column 2, and a “V” or “I” must be entered in column 3, and vice versa. [10/01/2015b] • 1060S ‐ The cost report preparer information (Worksheet S‐2‐1, lines 15 through 17, all columns) must be valid and present. [10/01/2015b]

10/1/2018 37

1728‐94 Transmittal 18

• New Edits • Numerous edits to ensure accuracy of HHA‐Based Hospice units • 1200S ‐ If Worksheet S‐5, column 4, line 10, is greater than zero, then Worksheet O‐1, column 7, line 100, must be greater than zero, and vice versa. [09/30/2016] • 1210S ‐ If Worksheet S‐5, column 4, line 10, is greater than zero, then Worksheet O‐1, column 7, line 100, must be greater than zero, and vice versa. [09/30/2016] • 1220S ‐ If Worksheet S‐5, column 4, line 12, is greater than zero, then Worksheet O‐3, column 7, line 100, must be greater than zero, and vice versa. [09/30/2016] • 1230S ‐ If Worksheet S‐5, column 4, line 13, is greater than zero, then Worksheet O‐4, column 7, line 100, must be greater than zero, and vice versa. [09/30/2016] • 1240S ‐ Worksheet S‐5, line 15, columns 1, 2, or 3, cannot be greater than Worksheet S‐5, line 12, columns 1, 2, or 3, respectively. [09/30/2016] • 1250S ‐ Worksheet S‐5, line 16, columns 1, 2, or 3, cannot be greater than Worksheet S‐5, line 13, columns 1, 2, or 3, respectively. [09/30/2016] • 1260S ‐ If Worksheet S‐5, column 4, line 15, is greater than zero, then Worksheet O‐3, column 7, line 25, must be greater than zero, and if Worksheet S‐5, column 4, line 16, is greater than zero, then Worksheet O‐4, column 7, line 25, must be greater than zero. [10/01/2015b and ending on or after 09/30/2016]

10/1/2018 38 265‐11 Transmittal 4

• ESRD Transmittal 4 • CMS issued Transmittal 4 on February 16, 2018 • HFS was approved by CMS for Transmittal 4 on April 6, 2018 • HFS released Transmittal 4 on April 13, 2018 • Effective Date ‐ Cost Reporting Periods Ending on or After December 31, 2017

The primary change in Transmittal 4 was the incorporation of a Worksheet S, check box to the certification and settlement summary statement for electronic signature submission to the ESRD cost reporting forms. This provision is available as an option for cost reporting periods ending on or after 12/31/2017 in accordance with 42 CFR 413.24(f)(4)(iv).

10/1/2018 39

265‐11 Transmittal 4

• Other Changes –Worksheet S, Part III

10/1/2018 40 265‐11 Transmittal 4

• Other Changes –Worksheet S, Part II.

10/1/2018 41

265‐11 Transmittal 4

• Other Changes –Worksheets B and C • Added cost and statistics for Acute Kidney Injury costs and treatments

10/1/2018 42 265‐11 Transmittal 4

• Other Changes –New Edits • Multiple new Level One Edits added the following edit is causing issues.

• Edit is hitting where ESRD provides all ESRD treatments as training or in the patient home. Note that the instructions to Worksheet S‐1 include the following:

10/1/2018 43

224‐14 FQHC Transmittal 2

• FQHC Transmittal 2 • CMS issued Transmittal 2 on March 9, 2018 • HFS was approved by CMS for Transmittal 2 on April 17, 2018 • HFS released Transmittal 2 on April 17, 2018 • Effective Date ‐ Cost Reporting Periods Ending on or After December 31, 2017

The primary change in Transmittal 2 was the incorporation of a Worksheet S, check box to the certification and settlement summary statement for electronic signature submission to the FQHC cost reporting forms. This provision is available as an option for cost reporting periods ending on or after 12/31/2017 in accordance with 42 CFR 413.24(f)(4)(iv).

10/1/2018 44 224‐14 FQHC Transmittal 2

• Other Changes –Worksheet S

10/1/2018 45

224‐14 FQHC Transmittal 2

• Other Changes • Worksheet S‐1, Part I (main facility)

• Worksheet S‐1, Part II (sub facilities)

10/1/2018 46 224‐14 FQHC Transmittal 2

• New Edits –To ensure the new lines on Worksheet S‐1, Parts I and II are completed:

10/1/2018 47

224‐14 FQHC Transmittal 2

• New Edits –For data integrity (applicable to 12/31/2017 FYEs)

10/1/2018 48 1984‐14 Hospice Transmittal 3

• Hospice Transmittal 3 • CMS issued Transmittal 3 on April 13, 2018 • HFS was approved by CMS for Transmittal 3 on April 20, 2018 • HFS released Transmittal 3 on April 26, 2018 • Effective Date ‐ Cost Reporting Periods Ending on or After December 31, 2017

The primary change in Transmittal 2 was the incorporation of a Worksheet S, check box to the certification and settlement summary statement for electronic signature submission to the Hospice cost reporting forms. This provision is available as an option for cost reporting periods ending on or after 12/31/2017 in accordance with 42 CFR 413.24(f)(4)(iv).

10/1/2018 49

1984‐14 Hospice Transmittal 3

• Other Changes

10/1/2018 50 1984‐14 Hospice Transmittal 3

• Other Changes –Worksheet A A&G

• New line 42.50

10/1/2018 51

1984‐14 Hospice Transmittal 3

• New Edit

• Will be effective for FYE on or after 6/1/2018 but will require costs of over $1 for: • Capital Related Building & Fixtures • Capital Related Movable Equipment • Administrative and General • Volunteer Service Coordination • Registered Nurses • Medical Social Services • Hospice Aide and Homemaker Services • DME/Oxygen • Pharmacy or Drugs Changed to Patients

10/1/2018 52 On the Horizon

• Anticipated Changes • 2552‐10 T‐15 • Implement FY 2019 changes • New Home Office Cost Report • New Form Set Iterations • PRM‐II Chapter One Revision • General cost report instructions • Updated acceptability checklist • Updated for electronic signatures/filing

10/1/2018 53

The End

Questions?

Comments?

Eric Swanson [email protected]

10/1/2018 54 222‐17 Transmittal 1

• CMS Published 5/18/2018 • Effective for cost reporting periods ending on or after 9/30/2018 • Free‐Standing RHC • Or part of HHA/SNF • Hospital‐based on 2552‐10

10/1/2018 55

222‐17 Transmittal 1

• Certification/Statistical Data • Worksheet S – Status/Certification/Settlement Summary • S‐1 Part I, RHC identification data, Part II, sub RHCs in consolidated report • S‐2 –Previous 339 questions • S‐3, Statistical data

10/1/2018 56 222‐17 Worksheet S

10/1/2018 57

222‐17 Worksheet S

Provider indicates Amended report on Line 3 by indicating amendment #

10/1/2018 58 222‐17 Worksheet S

Medicare Utilization F –Full N‐ No (MAC may verify) L‐ Low (Requires prior contractor approval)

10/1/2018 59

222‐17 Worksheet S

Accommodates electronic signature

10/1/2018 60 222‐17 Worksheet S‐1, Part I

10/1/2018 61

222‐17 Worksheet S‐1, Part I

Worksheet S‐1, Part I completed for main facility • If consolidated line 3 “Y” with number of facilities and line 14 subscripted for facilities. • Each sub‐component listed on line 14 subscripts will complete a Worksheet S‐1, Part II

10/1/2018 62 222‐17 Worksheet S‐1, Part II

10/1/2018 63

222‐17 Worksheet S‐2

Worksheet S‐2 replaces the 339

10/1/2018 64 222‐17 Worksheet S‐3

• Lines 1, 3 and 5 subscripted for each sub‐facility. • Note these are Medical/Mental Health visits will not subsequently be broken out by type of practitioner (as in FQHC 224‐14) • Line 5 I&R visits subset of lines 1 and 3.

10/1/2018 65

222‐17 Worksheet A Series

• Worksheet A –Working Trial Balance • Worksheet A‐6 – Reclassifications • Worksheet A‐8 – Adjustments to Expenses • Worksheet A‐8‐1 –Cost of Services from Related Organizations and Home Office Costs

10/1/2018 66 222‐17 Worksheet B

Worksheet B, Part I – Application of Productivity Standards

10/1/2018 67

222‐17 Worksheet B

Worksheet B, Part II –Determination of total (including overhead) RHC costs

10/1/2018 68 222‐17 Worksheet B‐1

Worksheet B‐1 – Computation of Medicare Vaccine Costs

10/1/2018 69

222‐17 Worksheet C

Worksheet C, Part I –Determination of Rate for RHC Services

10/1/2018 70 222‐17 Worksheet C

Worksheet C, Part II –Determination of Total Payment

10/1/2018 71

222‐17 Worksheet C‐1

Worksheet C‐1 – Analysis of Payments to the RHC

10/1/2018 72 2088‐17 Transmittal 1

• CMS Published 5/18/2018 • Effective for cost reporting periods ending on or after 9/30/2018 • Free‐Standing Community Mental Health Center (CMHC)

10/1/2018 73

2088‐17 Transmittal 1

• Certification/Statistical Data • Worksheet S – Status/Certification/Settlement Summary • S‐1 Part I, CMHC identification data, • Part II, Statistical Data • S‐2 –Previous 339 questions • S‐3, Statistical data

10/1/2018 74 2088‐17 Worksheet S

10/1/2018 75

2088‐17 Worksheet S

Provider indicates Amended report on Line 3 by indicating amendment #

10/1/2018 76 2088‐17 Worksheet S

Medicare Utilization F –Full N‐ No (MAC may verify) L‐ Low (Requires prior contractor approval)

10/1/2018 77

2088‐17 Worksheet S

Accommodates electronic signature

10/1/2018 78