Impacts of CMS Transmittal 1681 Amending Worksheet S-10
Author: Michael Thomas
The July 15, 2016, Centers for Medicare & Medicaid Services Transmittal 1681 attempted to solidify the time frame for updating federal fiscal year (FFY) 2014 cost report information that can impact proposed FFY 2018–2020 Medicare Disproportionate Share Hospital reimbursement. The transmittal states that hospitals must submit revised Worksheet S-10 (S-10) information on amended cost reports by September 30, 2016, to be included in the FFY 2018 calculation.
While the introductory transmittal language states the deadline as September 30, historical application of Healthcare Cost Report Information System source data suggests this timing would be relevant for the FFY 2018 Proposed Rule. It’s possible a December 2016 deadline is relevant for the FFY 2018 Final Rule, but relying on the later deadline is inadvisable.
Regardless of the official due date for FFY 2014 data, the FFY 2015 and forward data is proposed to dramatically impact reimbursement. Providers should act now because a sufficient review of S-10 amounts and activities can take weeks.
BKD National Health Care Group is committed to uncompensated care (UC) issues and will soon release a series of articles on S-10 highlighting the inherent conflicts between the cost report instructions, UC reimbursement and financial reporting.
Here are some important steps to take now:
- Verify that detailed patient listings are available to support S-10 filed amounts
- Establish that filed amounts are compliant with cost report instructions
- Check that policies, procedures and reporting are compliant and consistent with one another
- Compare the impact of current cost report instructions on UC to the effect of potential changes to cost report instructions on UC
Contact your BKD advisor for information regarding the revision’s potential impact on your reimbursement and how you can prepare.