The recently published FY 2020 Hospital Inpatient PPS Final Rule contains important changes regarding the use of Worksheet S-10 data in the calculation of uncompensated care payments. These changes go into effect Oct. 1, 2019.
What are key takeaways from the FY IPPS 2020 Final Rule?
1. CMS will be using FFY 2015 Worksheet S-10 data to calculate Factor 3 for FY 2020. The primary reason for this decision is FY 2015 was the most recent year of data that CMS broadly allowed to be resubmitted by hospitals.
“Given that we have conducted audits of the FY 2015 Worksheet S-10 data and have previously used the FY 2015 data to determine uncompensated care payments and the fact that the proposed uncompensated care payments to hospitals whose FY 2015 Worksheet S-10 data were audited represent approximately half of the total proposed uncompensated care payments for FY 2020, we believe that, on balance, the FY 2015 Worksheet S-10 data are the best available data to use for calculating Factor 3 for FY 2020.”
2. CMS will likely continue to use just one year of data to calculate Factor 3, but they may consider returning to the use of a three-year average in the future.
“As we continue to audit additional years of the Worksheet S-10 data and monitor the stability of uncompensated care payments, we may consider the use of multiple years of audited Worksheet S-10 data in rulemaking for future years.”
3. CMS is currently auditing FFY 2017 Worksheet S-10s and has indicated 2017 data are being audited with the goal of having the data available for future rulemaking. To date, CMS has audited roughly 600 hospitals which account for approximately half of the uncompensated care pool for FY 2020.
“…we believe that the FY 2017 Worksheet S-10 data should be audited before they are used in determining Factor 3. To this end, we began auditing the FY 2017 Worksheet S-10 data in July 2019, with the goal [of] having the FY 2017 audited data available for future rulemaking.”
What can providers do to address these changes?1
- CMS will be using a June 30, 2019 HCRIS extract to calculate Factor 3 for the FY 2020 Final Rule. Hospitals should review Worksheet S-10 Line 30 of their most recent cost report to ensure the amount matches the published data. Hospitals have until August 31, 2019, to review and submit comments on the accuracy of the Factor 3 table and supplemental data file published in conjunction with the final rule.
- There’s no firm audit guidance from CMS yet, leaving many hospitals feeling unprepared. CMS audit process is ever evolving — going from many changes in the 2015 audits to less in 2017 audits. It’s important to note, CMS is consistent with requiring large amounts of data and sample sizes in some cases.
- Because the uncompensated care payment pool is capped each year, it’s critical hospitals complete their Worksheet S-10 correctly the first time. Once your Worksheet S-10 is audited, you can’t reopen it to adjust.
How can TransUnion Healthcare help?
TransUnion Healthcare’s Uncompensated Care Analytics solution was one of the first services offered in the industry to help hospitals complete Worksheet S-10.
This powerful solution provides the core data points needed to complete Worksheet S-10, as well as detailed documentation to facilitate the audit process, analysis of the impact your results will have on your uncompensated care payments, and benchmarking against peer hospitals.
1The materials available on this page are for informational purposes only and not for the purpose of providing legal advice. You should contact your attorney to obtain advice with respect to any particular issue or problem.
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