Medicare Cost Reporting Issues Wisconsin Office of Rural Health Financial Workshop August 19, 2009 Richard Donkle, Director of Financial Consulting Services Rural Wisconsin Health Cooperative Ed Hansmann, Audit Manager National Government Services

Items for Discussion Medicare Bad Debt ER Stand-By Costs Time Studies Alternative Allocation Methods Reporting Medicare Advantage Swing-Bed Days High Cost to Charge Ratios Amended Cost Reports Cost Report Form Changes 2

Medicare Bad Debts The Regulations 42 CFR states: The Bad debt must be related to covered services and derived from deductible & coinsurance. Must be a reasonable collection effort. The debt was actually uncollectible when claimed as worthless. Sound business judgment established that there is no likelihood of recovery in the future. 3

Medicare Bad Debts Combined (method II) Billing The bad debt on professional fees are not an allowable bad debt for Medicare. Auditors will disallow the coinsurance related to professional fees. The FISS screen show the coinsurance on all charges, including professional charges. 4

Medicare Bad Debt- Obtaining professional fees coinsurance Map screen 103H on FISS is the current map screen for seeing the coinsurance and deductible for each charge code. To get the screen use 02- Claim. Then 30 which is claim summary. Then put in the HIC number. Then enter the date of service. Look at the claim you want and put an S at the left Then go to page 31 which is the detail by hitting F6. Page 10 is the coinsurance and deductible for the claim. 5

Medicare Bad Debts Medicare Crossover Bad Debts – Providers must wait for a State denial before claiming the Medicare Bad Debt on the cost report. 6

Medicare Bad Debts Submit the an electronic copy of your Medicare Bad Debt list. The audit staff will then select a sample from their sampling program – called ACL. Bad debts if submitted to a collection agency will be allowed when the bad debt is considered worthless and returned from the collection agency. 7

ER Stand-By Costs Any physician fees - salaried or contracted must be shown on Worksheet A-8-2 Direct Patient Care and Administrative split via time studies. CAH is exempt from the RCE (Column 6) 8

ER Stand-By Costs (cont’d) Standby Costs are allowable administrative costs if documented -NGS recommends time studies two weeks out of each quarter identifying: - Direct patient care time - Administrative duties - Standby Time 9

ER Stand-By Costs (cont’d) However NGS will accept: The ER Patient Logs as a time study for the direct patient care time. If the facility also provides time the ER Dr. spends: -in house seeing hospital inpatients or -a signed statement saying the ER Physician had no in house visits. 10

ER Stand-By Costs (cont’d) For C/R periods beginning on or after 10/1/01, costs for E/R physicians who are on call but not present at the facility may be included if: -not furnishing physician services -not on call at any other provider or facility -incurred under a written contract 11

ER Stand-By Costs (cont’d) -immediately available by phone or radio -available to be on site on a 24 hour a day basis within 30 minutes or 60 minutes in areas described in 42 CFR (d)(2) 12

Time Studies for Physicians NGS recommends two weeks out of every quarter for a year. -must be signed by the physician to be valid -describe what they are doing in 15 minute increments - Summarize information to develop the split 13

Time Studies – Non-Physician (cont’d) Periodic Time Studies -Periodic time studies, in lieu of ongoing time reports, may be used to allocate direct salary and wage costs. However, the time studies used must meet the following criteria: 14

Time Studies – Non-Physician (cont’d) The time records to be maintained must be specified in a written plan submitted to the intermediary no later than 90 days prior to the end of the cost reporting period to which the plan is to apply. The intermediary must respond in writing to the plan within 60 days from the date of receipt of the request, whether approving, modifying, or denying the plan. 15

Time Studies – Non-Physician (cont’d) A minimally acceptable time study must encompass at least one full week per month of the cost reporting period. Each week selected must be a full work week (Monday to Friday, Monday to Saturday, or Sunday to Saturday). 16

Time Studies – Non-Physician (cont’d) The weeks selected must be equally distributed among the months in the cost reporting period, e.g., for a 12 month period, 3 of the 12 weeks in the study must be the first week beginning in the month, 3 weeks the 2nd week beginning in the month, 3 weeks the 3rd, and 3 weeks the fourth. 17

Time Studies – Non-Physician (cont’d) No two consecutive months may use the same week for the study, e.g., if the second week beginning in April is the study week for April, the weeks selected for March and May may not be the second week beginning in those months. 18

Time Studies – Non-Physician (cont’d) The time study must be contemporaneous with the costs to be allocated. Thus, a time study conducted in the current cost reporting year may not be used to allocate the costs of prior or subsequent cost reporting years. 19

Time Studies – Non-Physician (cont’d) The time study must be provider specific. Thus, chain organizations may not use a time study from one provider to allocate the costs of another provider or a time study of a sample group of providers to allocate the costs of all providers within the chain. 20

Alternative Allocation Methods The following overhead cost center statistics can be substituted for the recommended statistics printed on Worksheet B-1. The 90-day and 60-day notification rule applies, as well as capital consistency: Housekeeping Square Footage Cafeteria FTEs Maintenance of Personnel Eliminated and moved to A&G Medical Records Gross Patient Revenue 21

Alternative Allocation Methods Requests for a change in allocation basis on worksheet B-1 of the Medicare Cost Report should be mailed to the field audit manager in charge of your facility. 22

Reporting Medicare Advantage Swing- Bed Days Where to include swing bed days for Medicare Advantage patients? Medicare HMO days should be reported on Worksheet S-3, line 3, column 6 (total) but not column 4 (T-18). 23

High Cost to Charge Ratios 24 High cost to charge ratios. If cost to charge ratios exceed 1.00 – NGS will review and determine if should be scoped for audit based upon materiality and consistency with prior years.

Amended Cost Reports If there have been changes to the as filed cost report. The provider should amend the cost report if Material. Helps in the completion of the Desk Review or audit. For example, Medicare Bad Debts samples need to be taken by the auditors from the correct list. Protects your appeal rights – Appeals are now handled by the Appeals area. 25

Cost Report Form Changes A notice published by the Centers for Medicare and Medicaid Services (CMS) on July 2, 2009, requests Office of Management and Budget approval for a revised Hospital and Hospital Health Care Complex Cost Report, proposed to take effect for cost reporting periods beginning on or after February 1, 2010 (new form CMS will replace existing form CMS ). 26

Cost Report Form Changes (cont’d) Such revisions mark the first major change to the hospital cost reporting form since In a supporting statement, CMS explained that the revisions are necessary to: Clarify existing instructions and definitions Standardize reporting of legislative and policy changes incorporated in the prior version of the cost report through transmittal updates Standardize subscripted lines and renumber forms (Adds line for implantable devices) 27

Cost Report Form Changes Reorganize data on Worksheet S-2 for better flow Remove obsolete worksheets Delete obsolete cost centers Assign standard reporting lines and incorporate settlement worksheets for psychiatric facilities or subproviders, IRFs or subproviders and LTCHs Include a worksheet for IME and GME 28

Cost Report Form Changes Include Worksheet S-2, Part II, in order to incorporate data previously reported on form CMS-339 (Provider Cost Report Reimbursement Questionnaire); require electronic submission as part of the cost report electronic filing and eliminate separate submission of the Form CMS-339 Include Worksheet S-3, Part IV to collect wage information previously reported on the Form CMS

Cost Report Form Changes Include Worksheet S-3, Part V to collect contract labor and benefit costs Redesign numerous worksheets for more efficient collection of data 30

Cost Report Form Changes CMS is accepting comments (electronically or by mail) on the proposed revisions until August 31, For more information on submitting comments, see the July 2, 2009, Federal Register at 74 Fed. Reg. 31,738. Detailed information relating to the revised cost report, including summaries of proposed revisions and proposed revised cost reporting instructions, are available on the CMS website under “downloads.” 31

Questions? Thank you