On April 24, 2018, CMS released its fiscal year 2019 hospital inpatient prospective payment system (IPPS) proposed rule (the Proposed Rule), in which the agency has proposed a number of changes to supporting documentation providers would be required to submit in connection with their annual Medicare cost reports. Among the more significant cost report-related proposals, CMS proposes that cost reports would be rejected for lack of supporting documentation if they do not include the following documentation:
- Intern and resident information system (IRIS) data—Teaching hospitals' cost reports filed on or after October 1, 2018, would be rejected if provider fails to submit IRIS data containing the same total counts of "weighted" and "unweighted" direct graduate medical education (DGME) full-time equivalent (FTE) residents and indirect medical education (IME) FTE residents as the total counts of DGME and IME FTE residents reported in the hospital’s cost report.
- Bad debt—Providers claiming Medicare bad debt reimbursement for cost reporting periods beginning on or after October 1, 2018 would need to submit a detailed Medicare bad debt listing, including patients' names, dates of service, Medicaid status (if applicable), dates collection efforts ceased, and deductible and coinsurance amounts, which listing must correspond to the bad debt amounts claimed in the provider’s cost report.
- Disproportionate share hospital (DSH) payments—For cost reporting periods beginning on or after October 1, 2018, hospitals claiming a DSH payment adjustment would be required to submit a detailed listing of their Medicaid eligible days that corresponds to the Medicaid eligible days claimed in the cost report. Similarly, an amended cost report that changes a provider's Medicaid eligible days would need to include an amended listing (or an addendum to the original listing) that corresponds to the Medicaid eligible days claimed in the amended cost report.
- Charity care—Hospitals reporting charity care and/or uninsured discounts for purposes of receiving the additional uncompensated care payment for DSH-eligible hospitals in cost reporting periods beginning on or after October 1, 2018 would be required to include a detailed listing, including patients' names, dates of service, insurers (if applicable), and the amounts of charity care and/or uninsured discounts given, which listing must correspond to the amounts claimed in the hospital’s cost report.
- Home office allocations—Finally, and also for cost reporting periods beginning on or after October 1, 2018, CMS proposes that providers claiming allocated home office or chain organization costs would be required to submit a home office cost statement completed by the home office or chain organization that corresponds to the amounts allocated to the provider’s cost report.
The proposals summarized above begin on page 1448 of the display copy of the Proposed Rule, which is scheduled to be published in the Federal Register on May 7, 2018. Comments are due to CMS by June 25, 2018.
IN RELATED NEWS, the new Medicare Cost Report e-Filing (MCReF) system went live this week. As of May 1, Medicare Part A providers can use MCReF to submit cost reports for provider fiscal years ending on or after December 31, 2017. The agency's informational presentation from a national provider call held on May 1 can be viewed here. An audio recording and transcript of the call will shortly be made available on the CMS website.