The next round of Missouri Medicaid disproportionate share hospital (DSH) surveys is upon us, and it’s important to remember the implications of the survey and consider any new requirements. Consistent with prior DSH surveys, any overpayments identified during the state fiscal year (SFY) 2013 examination will be subject to recoupment by the state. This makes it extremely important for you to file the survey as accurately and completely as possible. The contractor has set an initial due date of January 29 to file DSH surveys and all supporting documentation.
In addition to the examination requirements, the data gathered will be used to determine a hospital’s SFY 2017 Medicaid DSH interim payment per 13 CSR 70-15. Under this regulation, hospitals are required to submit surveys and documentation to the contractor no later than March 1; otherwise, they won’t be eligible to receive a payment for the SFY beginning on July 1, 2016.
Here are some of the significant changes to the SFY 2013/2017 DSH surveys and exhibits:
- There still is a significant push for hospitals to report other Medicaid-eligible data on the survey. Per The Additional Information on the DSH Reporting and Audit Requirements FAQ No. 33, “Days, cost and revenues associated with patients that are eligible for Medicaid and also have private insurance should be included in the calculation of the hospital-specific DSH limit.” Examples of this population could include patients with Medicaid where Medicaid didn’t pay due to reasons such as not filing timely or lack of precertification. Remember: The patient must have active Medicaid coverage at the time of service and receive a service ordinarily covered by Medicaid. Other examples may include patients with commercial insurance or Medicare Managed Care insurance as primary and Medicaid as secondary. Particularly if Medicaid didn’t have cost sharing on the claim, the claim might not be included in the state Medicaid fee-for-service data but should be reported on the survey. It’s the hospital’s responsibility to review claims data and avoid duplication. If other Medicaid-eligible data isn’t reported, the contractor has included an edit in the survey to bring hospitals’ attention to the exclusion of this data. The contractor also may follow up with hospitals directly to submit this information.
- The “Exhibit C” file used to report the hospital’s internal data was updated to include two additional columns for reporting Medicare Managed Care and Medicaid Managed Care payments. It’s important for hospitals to use all payment columns to differentiate the types of payments reported. Litigation is pending over the allowability of certain types of payments included in the DSH calculation; if this litigation finds the Centers for Medicare & Medicaid Services (CMS) is improperly enforcing FAQ No. 33, certain payment columns may be removed, increasing hospitals’ uncompensated care cost.
- Finally, the survey form also was updated to include lines for reporting any nonhospital-related charity care charges or cash subsidies. These nonhospital services could include professional revenues, rural health clinics, home health agencies, swing beds, etc. The data reported on these lines is used solely in the Low Income Utilization Ratio (LIUR), a data element that must be reported to CMS but has no bearing on calculating uncompensated care cost for Missouri hospitals.
As you gather the information and complete the surveys, consider the above items so you’ll file a survey in accordance with current guidelines and CMS regulations.
If you have additional questions or would like more information on this matter, contact your BKD advisor.