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Health Financial Systems Presentation for SW OH HFMA Luke DiSabato luke@hfssoft.com 1
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Objectives Major Cost Report Changes – Hospital - Review of 2552-10 T-8 – FQHC PPS (Final 224-14) – New Hospice Cost Report – 1984-14 Potential issues for other provider types – SNF 2540-10 – HHA 1728-94 – ESRD 265-11 – RHC 222-92 – CMHC 2088-92 – OPO 216-92 2
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3 Transmittal 8 Changes Worksheet S-2 – Instructions for Lines 3 – 17 clarified to better define PPS/TEFRA/Other. – Adds “sub clause” II LTCH provider type to TEFRA – One known LTCH identified and will be paid similar to TEFRA with no bonus/incentive payment. Recent Cost Reporting Changes Hospital 2552-10 T-8
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Form Changes Worksheet S-2 4 Transmittal 8 Use Columns 1 and 2 for 10/1 split for 12/31/2015 report
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Form Changes E, Part A 5 Transmittal 8 Use Worksheet E, Part A, lines 1.01 and 1.02 for DRG split at 10/1
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FFY 2015 Final Rule Cost Report Provisions Wage Index – New OMB Designations effective – Based on 2010 Census Data – New CBSA Definitions New Urban/Rural designation – 37 Counties (12 hospitals) were urban now rural 3-year transition for wage index Not for DSH – 105 Counties (81 hospitals) were rural now urban Transition if rural wage index was higher – Movement between CBSA Transition period If lower – one year blend DSH - Providers designated as rural that were urban prior to CBSA changes – Three year phase in Year one payment for 2/3 difference Year two payment for 1/3 difference 6
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Form Changes Worksheet S-2 7 Transmittal 7 Line 22.02 added to identify newly merged hospitals Line 22.03 added to identify hospitals reclassified as a result of CBSA changes.
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Form Changes Worksheet S-2 Line 87 added for sub-clause II LTCH Line 145, column 2 added to identify no Medicare dialysis utilization. 8 Transmittal 8
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Form Changes Worksheet S-2 Line 168.01 added CAH with EHR hardship requirement for payment reductions that begin on or after FFY 2015 Line 169 modified to allow entry of 9.99 where provider has completed transition period 9 Transmittal 8
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Form Changes Worksheet S-3 Title XIX IPF and IRF HMO discharges will be reported on S-3, Part I, lines 3 and 4, column 14, for cost reporting periods beginning on or after October 1, 2014. 10 Transmittal 8
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Form Changes Worksheet S-3 Line 18 – “Subprovider” 11 Transmittal 8
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Form Changes Worksheet S-3 Line 21 – “Other Long Term Care” 12 Transmittal 8
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Form Changes Worksheet E, Part A Lines 35 and 35.01 – In most cases lines 35 and 35.01 blank and line 35.02 will flow from CMS tables. 13 Transmittal 7 For 12/31/2014 report column 1 will represent FFY 2014 pool allocation and column 2 will reflect FFY 2015.
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Form Changes Worksheet E, Part A Lines 35 and 35.01 – Will be computed where: – Hospital not paid UCC during cost reporting period – New provider – Merged Provider not in CMS table – SCH Hospital beginning FFY 2015 14 Transmittal 7
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Form Changes Worksheet E, Part A 15 Transmittal 7 Factor 3 from FFY 2015 table where: Not projected to receive DSH SCH Hospital
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UCC DSH FY16 Table CMS issued to the vendors the Pooled amount for FY16 to be $6,406,145,534.04. (we drop the 0.04) CMS has posted the UCC DSH Table at the following link: https://www.cms.gov/Medicare/Medicare-Fee-for-Service- Payment/AcuteInpatientPPS/FY2016-IPPS-Final-Rule-Home- Page-Items/FY2016-IPPS-Final-Rule-Data- Files.html?DLPage=1&DLEntries=10&DLSort=0&DLSortDir=asc ending https://www.cms.gov/Medicare/Medicare-Fee-for-Service- Payment/AcuteInpatientPPS/FY2016-IPPS-Final-Rule-Home- Page-Items/FY2016-IPPS-Final-Rule-Data- Files.html?DLPage=1&DLEntries=10&DLSort=0&DLSortDir=asc ending 16
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Form Changes Worksheet E Part A New lines on Worksheet E, Part A, for: – Line 70.89 - Pioneer Accountable Care Organization (ACO) payment adjustments (PS&R) – Lines 70.90 and 70.91 If an MDH was paid at the % of the HSP, the Hospital value-Based purchasing adjustment must be applied to the 75% HSR reimbursement. This is calculated on lines 100 – 104 – Line 70.99 – Hospital Acquired Conditions (HAC) payment adjustment from Exhibit 5. 17 Transmittal 7
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Form Changes Worksheet E Part A 18 Transmittal 7
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Form Changes Worksheet E Part A 19 Transmittal 7 – Lines 100-104 If an MDH was paid at the % of the HSP, the Hospital value-Based purchasing adjustment must be applied to the 75% HSR reimbursement.
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FFY 2015 Final Rule Cost Report Provisions Low Volume/MDH – LVA modified in ACA for FFY 2011 and 2012 – ATRA extended to FFY 2013 (10/1/2014) – Pathway for SGR Reform Act extended to 3/31/2014 – Protecting Access to Medicare Act of 2014 extended to 3/31/2015. – The Medicare Access and CHIP Reauthorization Act of 2015 extended to 9/30/2017. FFY 2015 Final Rule added to payments subject to LVA: – Net Organ Acquisition Costs – Credits for Replaced Devices 20
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Form Changes Exhibit 4 21 Transmittal 7
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FFY 2015 Final Rule Cost Report Provisions Hospital Acquired Conditions (HAC) reduction – Reductions on or after 10/1/2014 for risk hospitals – Adjustments applied after VBP and HRRP adjustments 22
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Form Changes Exhibit 5 23 Transmittal 7 Hospital Acquired Conditions (HAC) reduction Reductions on or after 10/1/2014 for risk hospitals Adjustments applied after VBP and HRRP adjustments
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Form Changes Exhibit 5 24 Transmittal 7 Hospital Acquired Conditions (HAC) reduction Reductions on or after 10/1/2014 for risk hospitals In FFY 2015 – 1% reduction for top 25 th Percentile
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Form Changes Worksheet E-3, Part V Line 6 revised to implement penalty for CAH providers not qualified as meaningful user and does not qualify for hardship exception. 25 Transmittal 8
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Form Changes Worksheet M Series Effective for cost reporting periods beginning on or after October 1, 2014, FQHCs filing as part of the hospital healthcare complex do not complete the Worksheet M series but complete the new FQHC PPS “N” series worksheets in Form CMS-2552-10 when they become available. 26 Transmittal 8
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IRIS Changes CMS has implemented an IRIS database in STAR (System for Tracking Audit and Reimbursement) and MACs are beginning to import the provider’s M & A dbf files and STAR is computing FTE counts to compare to the Medicare Cost Report. At some time in the future CMS will be instructing MACs to compare the FTEs and if there are differences between the STAR FTE count and the cost report. 27
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IRIS Changes To address this change, we have implemented a Special Report (SR923) page into the HFS IRIS software. You can find this by going to Forms – Open Forms and scrolling to the bottom. The following slide shows the new SR923 report. 28
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IRIS Changes 29
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IRIS Changes You can extract from HFS IRIS a csv file to load to the mcrx file for SR923, you get this file from the Residency Report – FTE Summary, it will be named xxxxx.FYB.FYE.SR923.csv. You go to the SR923 in the mcrx file and browse and find this file. If you do not use HFS IRIS, you can always manually key in the FTE counts. 30
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IRIS Changes We have introduced new Level II edits with the cost reporting software when the SR923 shows a difference between the MCRX and IRIS FTEs. 31
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Heads Up 2552-10 T-9 Published on CMS Website 3/18/2016 Effective for cost reporting periods beginning on or after 10/1/2015. MINOR Changes 32
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2552-10 Transmittal 9 Regulation Changes OPPS Final Rule – Federal Register 11/13/2015 Transition for Former Medicare Dependent Small Rural Hospitals (MDHs) – OMB revised delineations for CBSAs effecting 10/1/2014 – Some MDHs re-defined as urban – Could apply for rural status 33
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2552-10 Transmittal 9 Regulation Changes For MDHs reclassified as rural that have not reclassified to rural prior to 1/1/2016 – Transitional payment Discharges 1/1/2016 – 9/30/2016 – Federal rate plus two-thirds of 75% of the amount by which the Federal rate payments is exceeded by the HSR Discharges 10/1/2016 – 9/30/2017 – Federal rate plus one-third of 75% of the amount by which the Federal rate payments is exceeded by the HSR 34
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2552-10 Transmittal 9 Regulation Changes 8 prior MDH providers identified by CMS: 35 08-000644-0031 14-018445-0451 39-007249-0019 42-001951-0062
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2552-10 EC Files Files Created – EC______.15A1 (EC data file) – PI______.15A1.pdf (PI data file) – EC______.15A1.pdf (Certification page) – NO PI.exe file created SaFE available for pre-acceptance and file storage 339 NOT required – Exhibit 1 (Physician Attestation) and Exhibit 2 (Bad Debts) can still be completed using Tools|339 36
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FQHC Providers CMS published the new FQHC Cost Report Form CMS-224-14 on April 22, 2016. The new FQHC PPS system effective for cost reporting periods beginning on or after 10/1/2014 FQHCs will no longer be using 222-92 Form 224-14 to be used by FQHCs for cost reporting periods beginning on or after 10/1/2014 37
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FQHC Providers HFS was approved on April 22, 2016 and we released the system on April 29, 2016. 38
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FQHC Providers Very similar to 222-92 HFS will provide training in the near future. If you have the 222-92 system and need the 224-14, please contact us at support@hfssoft.com and let us know how many RHC reports you have and how many FQHC reports you need to file. support@hfssoft.com 39
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FQHC Providers 40
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Form CMS 224-14 Worksheet S 41 Part I – Updated to reflect new form set items Part II – Certification Part III- Settlement Summary
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Form CMS 224-14 Worksheet S-1, Part I 42 Similar to prior 222 All Physician Specific data eliminated Hours of operation information eliminated Line 8 for consolidated reports Request and approval date reported Separate S-1, Part II, for each FQHC Grant/Malpractice/I&R/Capital question added by FQHC
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Form CMS 224-14 Worksheet S-2 43 Incorporated Appropriate 339 Questions
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Form CMS 224-14 Worksheet S-3, Part I 44 Breakout Title and total visits by: Medical visit Mental health visit Visits performed by I&Rs And by each facility
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Form CMS 224-14 Worksheet A Series 45 Worksheet A – Reclassification and Adjustment of WTB Worksheet A-1 – Reclassifications Worksheet A-2 – Adjustments to Expenses Worksheet A-2-1 – Related Organization Costs
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Form CMS 224-14 Worksheet A Series Only the following cost centers can be subscripted. 46
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Form CMS 224-14 Worksheet B 47 Other Direct and General Service costs allocated on accumulated costs (No alternate methods of allocation) Total costs allocated to Title XVIII based on visits Medical Mental Health If applicable I&R costs allocated based on I&R visits
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Form CMS 224-14 Worksheet E 48 Settlement includes FQHC PPS Payment DGME (if applicable) Vaccine costs Bad Debts
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Other Form Sets Hospice 1984-14 published by CMS – Effective for cost reporting periods beginning on or after 10/1/2014 – HFS Software approved 10/24/2014 and released 11/3/2014 49
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Form 1984-14 Significant Changes Will utilize modern EC/PI file naming – 14A1 (Year, multiple reports in single year, initial/amended) Worksheet S indicator for Low/No Utilization Worksheet S-2 added and replaces Form CMS- 339 50
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Form 1984-14 Significant Changes Continued Three Categories of Costs – General Service Cost Centers (Overheads) – Direct Patient Care Service Cost Centers – NonReimbursable Cost Centers For all Direct Patient Care Service Cost Centers salary and other costs must be identified by Level of Care -A-1 Continuous Home Care -A-2 Routine Home Care -A-3 Inpatient Respite Care -A-4 General Inpatient Care 51
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Review of Worksheet Changes 52 General Service Cost Centers (Overheads) -Expanded overhead cost centers -Must use statistical basis on forms unless approved for alternate method 1984-99 1984-14
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1984-14 Transmittal 2 Changes Previously a Level One Edit 53
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1984-14 EC Files Files Created – HS______.15A1 (EC data file) – PI______.15A1.pdf (PI data file) – HS______.15A1.pdf (Certification page) – NO PI.exe file created SaFE available for pre-acceptance and file storage 339 NOT required 54
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RHC/FQHC Form 222-92 Transmittal 12 – Effective for cost reporting periods beginning on or after 10/1/2014 – Published on CMS website September 2015 – Software update released 11/6/2015 55
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Form 222-92 Transmittal 12 The primary purpose for this transmittal is to implement edits prohibiting the use of Form 222-92 by FQHCs, for cost reporting periods beginning on or after October 1, 2014. Due to the implementation of a revised PPS effective for cost reporting periods beginning on or after October 1, 2014, CMS has proposed a new cost reporting Form CMS-224-14, for FQHC providers. The following edits have been added: – Level One edit 1021S – If Worksheet S, Part I, line 5, column 3, is “2” (indicating an FQHC), then Worksheet S, Part I, line 4, column 1 (cost report period begin date), cannot be on or after October 1, 2014. – Level one edit 1031S – For any FQHC providers filing a consolidated cost report, Worksheet S, Part III, line 6, column 2, (certification date for additional providers) cannot be after October 1, 2014. In addition Transmittal 12, shaded the Worksheet B-1, columns 2.01 and 2.02, for H1N1 vaccines, effective for cost reporting periods beginning on or after October 1, 2014. 56
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Form 222-92 Transmittal 12 The primary purpose for this transmittal is to implement edits prohibiting the use of Form 222-92 by FQHCs, for cost reporting periods beginning on or after October 1, 2014. Due to the implementation of a revised PPS effective for cost reporting periods beginning on or after October 1, 2014, CMS has proposed a new cost reporting Form CMS-224-14, for FQHC providers. The following edits have been added: – Level One edit 1021S – If Worksheet S, Part I, line 5, column 3, is “2” (indicating an FQHC), then Worksheet S, Part I, line 4, column 1 (cost report period begin date), cannot be on or after October 1, 2014. – Level one edit 1031S – For any FQHC providers filing a consolidated cost report, Worksheet S, Part III, line 6, column 2, (certification date for additional providers) cannot be after October 1, 2014. In addition Transmittal 12, shaded the Worksheet B-1, columns 2.01 and 2.02, for H1N1 vaccines, effective for cost reporting periods beginning on or after October 1, 2014. 57
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222-92 EC Files Files Created – RF______.15A (EC data file) – PI______.15A (PI data file) – RF______.15A.pdf (Certification page) – NO PI.exe file created SaFE NOT available 339 still required but streamlined 58
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SNF 2540-10 No significant changes – Changes for FQHC PPS and Hospice form changes not yet incorporated – CMS did issue draft FQHC Effective cost reporting periods beginning 10/1/2014 – Would file a separate 224-14 when available Hospice reporting changes – Worksheet O series added similar to 1984-14 – CMS has indicated this will be applicable for cost reporting periods beginning on or after 10/1/2015 59
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SNF 2540-10 Files Created – SN______.15A1 (EC data file) – PI______.15A1.pdf (PI data file) – SN______.15A1.pdf (Certification page) – NO PI.exe file created SaFE available for pre-acceptance and file storage 339 NOT required Exhibit 1 (Bad Debts) can still be completed using Tools|339 60
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HHA 1728-94 No significant changes – Changes for Hospice form changes not yet incorporated CMS did issue draft – Form S-2-1 added and replaces Form CMS-339 – Hospice form changes (effective for cost reporting periods beginning on or after 10/1/2015). Added Worksheet S-5, Parts III&IV to replace Parts I & II Added O Series of Worksheets to replace the current K series – Obsolete Forms deleted S-6 and J series for CORF (fee-based) RH and FQ series (cannot have an HHA-based clinic) 61
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HHA 1728-94 EC Files Files Created – HH______.15A (EC data file) – PI______.15A (PI data file) – HH______.15A.pdf (Certification page) – NO PI.exe file created SaFE NOT available 339 still required but streamlined 62
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ESRD 265-11 No significant changes Recurring issues – Use of columns 4 and 6 on Worksheet D – Edit 1010E CMS to contract for 1400+ ESRD audits. https://www.cms.gov/Regulations-and- Guidance/Guidance/Transmittals/2016-Transmittals- Items/R1640OTN.html?DLPage=1&DLEntries=10&DLSort =1&DLSortDir=descending 63
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ESRD 265-11 Use of Columns 4 and 6 64
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ESRD 265-11 Worksheet E, Line 2 65
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ESRD 265-11 Use of Columns 4 and 6 66 May trigger level one edit if using PS&R reconciliation tool due to rounding
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ESRD 265-11 Files Created – RD______.15A1 (EC data file) – PI______.15A1.pdf (PI data file) – RD______.15A1.pdf (Certification page) – NO PI.exe file created SaFE available for pre-acceptance and file storage 339 NOT required Exhibit 1 (Bad Debts) can still be completed using Tools|339 67
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HELP Main phone line 888-216-6041 – Coverage from 5am – 5pm PST Email issues to support@hfssoft.comsupport@hfssoft.com – Include applicable.mcrx and other applicable files 68
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Filing Tips Correcting Invalid Cost Center Codes 69 In T-7 CMS CC code changes Limited many non-standard cost center codes to usage of (1) Changed “Other Reimbursable” from 03850 to 09850 Use of prior year codes could result in level one edits
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Filing Tips Correcting Invalid Cost Center Codes 70 To resolve: In “Edit|Cost Center and Statistics” Highlight cost center Select appropriate code Hit “Apply” Or send.mcrx file to support@hfssoft.com
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Filing Tips “New” Filenames 71 Previously all “New” files named new.mcrx Form type now identified in new file name HFS highly recommends use of descriptive file names
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Filing Tips EC Files Created for.mcrx Systems The following files will be created and exported to the CD\Flash Drive – EC______.15A1 (EC File) – PI______.15A1.pdf (Print Image File) – EC______.15A1.pdf (PDF of Signature page) “1” will be incremented for amended reports Backup copies will also be saved to the.mcrx directory PI______.exe no longer created 72
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Filing Tips EC Files Created for.mcrx Systems The following files will be created and exported to the CD\Flash Drive – EC______.15A1 (EC File) – PI______.15A1.pdf (Print Image File) – EC______.15A1.pdf (PDF of Signature page) “1” will be incremented for amended reports Backup copies will also be saved to the.mcrx directory PI______.exe no longer created 73 TYPE OF PROVIDERFILE NAME DESIGNATOR Hospital (2552-10)(2552-96)EC SNF (2540-10)(2540-96)SN Home Health Agency (1728-94)HH CMHC (2088-92)CM Rural Health Clinic (222-92)RF ESRD (265-11)(265-94)RD Hospice (1984-14)(1984-99)HS Organ Procurement Organization (216-94) OP
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Filing Tips EC Files Created for.mcrx Systems 74 For amended report Worksheet S, Part 1, line 3, reflects amended Still first submission UNLESS second submission in a calendar year.
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PI file and “encryption code” – Placed at end of PI______.15A1.pdf file – Can only be viewed using notepad – Do NOT save changes to.pdf of encryption code will be lost. 75 Filing Tips EC Files Created for.mcrx Systems
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76 Filing Tips EC Files Created for.mcrx Systems
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Filing Tips EC Files Created for.mcr Systems The following files will be created and exported to the CD\Flash Drive – EC______.15A (EC File) – PI______.15A (Print Image File) – EC______.15A.pdf (PDF of Signature page) Backup copies will also be saved to the.mcr directory PI______.exe no longer created 77
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PI file and “encryption code” – Placed at end of PI______.15A file – Can be viewed using notepad – Do NOT make any changes to PI file in notepad. 78 Filing Tips EC Files Created for.mcr Systems
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79 Filing Tips EC Files Created for.mcr Systems
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HFS Store and File Electronically 80
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Provider Electronic Filing - SaFE Export | Create ECR File Available in 2552-10, 2540-10, 265-11 and 216-94. 81
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Provider Electronic Filing - SaFE Why would providers want to do this? 1.Acceptance Pre-Scan 2.Comparison to Prior Year HCRIS Data 3.Cost Report Storage 82
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Provider Electronic Filing - SaFE 83 Uses STAR MAC info to predict the provider’s MAC.
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Provider Electronic Filing - SaFE Does not replace submission of data to your MAC. 84
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Provider Electronic Filing - SaFE Files submitted – EC, PI,.mcrx,.pdf,.mcp,.aaix 85
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Provider Electronic Filing - SaFE Files are transmitted to the HFS SaFE website…. 86
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Provider Electronic Filing - SaFE 87
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Provider Electronic Filing - SaFE 88
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Provider Electronic Filing - SaFE E-mail Reply based on Login Information – Cost Report Preparer Information 89
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Provider Electronic Filing - SaFE 2 nd E-mail to let you know when processing is complete. 90
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Provider Electronic Filing - SaFE 91
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SaFE – User Account Storage 92
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SaFE – User Account Storage File Storage/Retrieval and Processing 93
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SaFE – User Account Storage 94
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SaFE – HCRIS Compare Reports 95
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HCRIS Database HCRIS Overview Future Enhancements New Look “My Provider List” Tools – My Provider Multi Facility Comparisons – Wage Data Analysis by CBSA – My Provider Roll Up Report(s) – Available Facility Reports Advanced Search and Extract Snapshot Reports 96
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HCRIS Overview – Joint HFS and Toyon Associates Venture. – Web based – Public Use Files (PUFs). Quarterly release by CMS and not in a readily useable format. HFS puts these files into a useable and readable format. HFS starts the upload of these PUFs as soon as they are released. HFS has created a database of nearly 800,000 reports. 1.Hospital – 255,00 reports2. SNF – 265,000 3.Health Clinics – 13,500 4. HHAs – 149,0005. ESRDs – 83,0006. Hospice – 28,500 7. CMHCs – 1,100 – Missing Reports? HFS involvement to research and add missing reports reported by our Users, has improved the completeness of the PUFs – 2552-10 and 2552-96. Can recreate an MCRX and PDF file for 2552-10 (missing data in 2552-96 HCRIS file). Can extract ANY available data for BOTH 2552-10 and 2552-96 SnapShot Reports and other tools for BOTH 2552-10 and 2552-96
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HCRIS Overview, cont.d – Formsets Status Hospital 2552-10 and 2552-96 – Has been available since 2011 SNF 2540-96 and 2540-10 – Still testing, but soon to be released for purchase. – Available Facility Reports\Advance Search and Extract\S-7 Snap-shot report Health Clinics 222-92 – In programming\development stage Renal Dialysis, HHA, Hospice, and CMHC next. – MCRX File Naming Convention AO_xxxxxx_mmddyyyy.555289.mcrx FO_xxxxxx_mmddyyyy.555290.mcrx – AO denotes an “as submitted” file – FO denotes a “Settled” file – xxxxxx is the Provider Number – mmddyyyy is the FYE (i.e. 12/31/2013) – 555289,555290, etc., is the HCRIS Record number to give EACH file a unique file name.
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Future Enhancements – More Reports for each System – Single Sign On with ALL HFS Websites, HFS, HCRIS and SAFE Ability to sign on one system and navigate to other systems without signing in again. – Have ALL Systems Available for Extract, Including Home Health Agencies, Hospice, Renal Dialysis, Health Clinics and CMHC.
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Functionality of the New Provider List 100
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Functionality of the New Provider List 101
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Searching for Providers 102
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Available Facility Reports
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Advanced Search and Extract
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HFS User Meeting Last Meeting – August 2015 in Nashville, TN – 300 Attendees, great software info and guest speakers Next Meeting – October 13-14 in Denver, CO 105
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THANK YOU HFS is grateful for the opportunity to present to SW OH HFMA. We welcome your feedback and will continue to make improvements based on your input. 106
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