Pete Harmon's HFS Blog

CMS has further extended the due dates for the new 265-11, ESRD cost report.  The 265-11 is effective for services rendered on or after 1/1/2011, but is not yet available.  Therefore, CMS issued extensions until 11/30/2011, but realized this was not sufficient, so CMS has further extended the due date to 1/31/2012.  ESRD cost reports due to be filed on the new 265-11, with FYE of 1/31/2011 through 5/31/2011, are now due 1/31/2012 (instead of 11/30/2011).  The 6/30/2011 FYE are expected to file on the normal due date of 1/31/2012.  Similarly, 7/31/2011 FYE, and thereafter, will file on the normal due date, of 5 months after the FYE.  HFS is in the process of obtaining approval for our 265-11 system, and will advise all when it is completed.  The new 265-11 Forms and Instructions may be found on our web site, www.hfssoft.com.

CMS has issued Transmittal 3 (T. 1 and T.2 were clean up of the original forms and instructions), as the Final 2540-10 Forms and Instructions.  These are posted on our web site, www.hfssoft.com and can be downloaded/printed at your convenience.  They should also be available on the CMS web site, as the 2540-10, Chapter 41, of CMS Pub 15-2.  The 2540-10 is effective for FY Begin 12/1/2010 and after, and no extensions were granted.  Thus, the initial reports are expected to be filed by 4/30/2012.  We are in the process of obtaining CMS approval for our 2540-10 system, and will advise all, when this is completed.

CMS has “officially” confirmed the “proposed” extensions I originally posted on 7/13/2011.  They are repeated here.  The only change was in the handling of short period reports.

FYE                              Due                    Now Due                    Extension

4/30/2011             9/30/2011        11/30/2011              60 days

5/31/2011             10/31/2011       11/30/2011             30 days

6/30/2011            11/30/2011        1/31/2012               60 days

7/31/2011            12/31/2011        1/31/2012                30 days

8/31/2011            1/31/2012           2/29/2012                30 days

9/30/2011           2/29/2012           3/31/2012                 30 days

10/31/2011         3/31/2012           3/31/2012                  NONE

 Short period reports beginning on or after 5/1/2010, but ending prior to 4/30/2011, must file and settle on the 2552-96.

 These cost reports are due the latter of 30 days from the date the forthcoming TDL (Technical Direction Letter), or 5 months following the close of the cost reporting period.  This includes hospitals with hospital based end stage renal disease (ESRD) facilities and/or departments.

Hospital based ESRDs are subject to the same extension schedule as indicated above.  Hospital based ESRDs should submit their cost reports using the current 2552-10, with the existing Worksheet I series.  The hospital based ESRDs claiming bad debts, may not be settled until a revised 2552-10, Worksheet I series is published incorporating the new bad debt calculation.

CMS has issued a new 2540-10 form set for the Skilled Nursing Facilities.  This is effective for FY Begin 12/1/2010 and after.  CMS is NOT proposing any extensions, as they believe approved software should be available by the time the 11/30/2011 FYE reports need to file (due 4/30/2012).  CMS has however, proposed that short period or terminating reports, with FY Begin 12/1/2011 and ending prior to 11/30/2011, be allowed to file and settle on the old 2540-96 forms.  The using of the 2540-96 is NOT yet final.  CMS is working on a Technical Direction Letter (TDL), and once this is issed, we will let everyone know.

CMS has issued a new Draft for the ESRD report, 265-11 form set, which is effective for services on or after 1/1/2011 (i.e. FYE 1/1/2011 or after).  As I posted earlier, this is still a Draft, and CMS does not expect a final until at least October 15, 2011.  Therefore, CMS has proposed cost report extensions (see below), but this is NOT yet final.  CMS is working on a Technical Direction Letter (TDL), which will make the extensions “official”.  When we see this TDL, we will let all clients know.  Once HFS has received the final forms and instructions, we will expedite our programming process, and obtain CMS approval, so we can issue updated software.  The proposed extensions are:

FYE                         Due                         Proposed Due              Extension

1/31/2011           6/30/2011          11/30/2011                 150 days

2/28/2011          7/31/2011           11/30/2011                 120 days

3/31/2011          8/31/2011            11/30/2011                 90 days

4/30/2011          9/30/2011           11/30/2011                 60 days

5/31/2011          10/31/2011          11/30/2011                 30 days

6/30/2011         11/30/2011          11/30/2011                  NONE

The 2552-10 Transmittal 2 is still in process at CMS.  T.2 is expected to clean up problems with Transmittal #1, as well as add changes made in the ACA (Affordable Care Act).  Once we receive T.2, we will begin the finaliztion process of the 2552-10.  CMS is preparing a Technical Direction Letter (TDL), and once issued, this will be the final 2552-10 extensions.

We are currently beta testing the new 2552-10 software in numerous sites across the country. Unfortunately, the new form set is still not final, and therefore, neither is our hospital software. CMS is still working on Transmittal 2. Transmittal 2 is needed is to fix various problems in Transmittal 1 (the current version of the 2552-10). Transmittal 2 will also implement numerous provisions of the ACA (Affordable Care Act), that were not included in Transmittal 1. We will work diligently to incorporate the Transmittal 2 changes into our 2552-10 software so that we may obtain CMS approval as quickly as possible. Once we obtain CMS approval we will release the 2552-10 software to all of our customers.

We realize many of you are concerned about the diminished time you will have to timely prepare and submit your hospital cost reports . We have expressed your concerns to CMS for many months now. CMS has proposed extensions for the 2552-10, but we have NOT received this as a final communication from CMS. (See table, below.) When we do, we’ll let everyone know. Until then, we can only wait on CMS 

FYE                              Due                    Proposed Due          Extension

4/30/2011             9/30/2011        11/30/2011              60 days

5/31/2011             10/31/2011       11/30/2011             30 days

6/30/2011            11/30/2011        1/31/2012               60 days

7/31/2011            12/31/2011        1/31/2012                30 days

8/31/2011            1/31/2012           2/29/2012                30 days

9/30/2011           2/29/2012           3/31/2012                 30 days

10/31/2011         3/31/2012           3/31/2012                  NONE

 For short period reports, beginning on or after 5/1/2010, and ending prior to 10/1/2010, will file and settle on the 2552-96.

 For short period reports, beginning on or after 10/1/2010, and ending prior to 4/30/2011, must file and settle on the 2552-10 (due 11/30/2011).

Any hospital report with a provider-based ESRD, ending 1/1/2011 through 3/31/2011, will file and settle on the 2552-10 transmittal revised for the new ESRD worksheets (I series), when available.  Due 11/30/2011.

Short period and terminating reports qualifying for the HIT Payment, will be granted extensions on a case by case basis, for cost reporting periods beginning on or after 10/1/2010, and file on the 2552-10.

Short period and terminating reports NOT qualifying for the HIT Payment, will file and settle on the 2552-96 with no extensions granted for cost reporting periods beginning on or after 10/1/2010, and ending on or before 4/30/2011.

CMS has published the final version of the SNF, 2540-0 cost report.  The 2540-10 is effective for FY Begin 12/1/2010 and after.  The final can be found at the URL below.

http://www.cms.gov/Manuals/PBM/itemdetail.asp?filterType=none&filterByDID=-99&sortByDID=1&sortOrder=ascending&itemID=CMS021935&intNumPerPage=10

Scroll down to Chapter 41 for SNF.  It is mis-labeled Home Health Agency, but it is the SNF.

HFS is working on these changes and will have software available in time for the initial filings, on 4/30/2012.  CMS is currently deciding what to do with short period and terminating reports, with FY Begin 12/1/2010 and after.  When I have something official on this, I will post it.

HFS received a Draft Transmittal 25 from CMS, on 4/21/2011.  T.25 rescinds the change made in T.23, to designate W/S E part A, line 24.97 and W/S E-1 line 3.49, for HCERA Payments (Health Care Education Reconciliation Act).  These payments are NOT Medicare Part A or B payments, and as such, it was decided they should not be reported in the cost report.  If you have any HCERA payments on W/S E part A line 24.97 or E-1 line 3.49, you must remove them.  HFS has added a Serious error message that if line 24.97 is not = 0, then you need to verify the data is not HCERA Payments.

T.25 also clarified the TOPS extension in T.24, was in fact for “small, rural” hospitals, as well as all SCH and all EACH hospitals.  T.24 did not specifically address “small, rural”, so CMS decided to clearly indicate they were extended for TOPS through 12/31/2011.  HFS had already known this, even though there was some ambiguity.  Therefore, we have had to make no calculation changes.

CMS has sent the 2540-10 to OMB for approval, and is avaiable at the CMS web site below.  The 2540-10, for Skilled Nursing Facilities (SNF), is to be effective for FY BEGIN 12/1/2010 and after.  The reason for the 2540-10 was to “clean up” the 2540-96.  Obsolete forms, lines, columns, were removed, some worksheets renumbered, and the instructions modified accordingly.  HFS has NOT received a “final” forms and instructions from CMS, so we don’t know when this new form set will be available to clients.  As we receive more information, I will post it.  The 2540-10 can be found at:

http://www.cms.gov/PaperworkReductionActof1995/PRAL/list.asp?filterType=none&filterByDID=0&sortByDID=2&sortOrder=descending&intNumPerPage=10

CMS has issued a new Draft form and instruction for the Free Standing ESRD, CMS 265-11.  This was required due to changes in MIPPA changing ESRD payment to PPS, effective for services on or after 1/1/2011.  There is a 4 year transition period, to phase in the full PPS (i.e. 25% PPS and 75% old composite rate, then 50/50, then 75/25, then 100% PPS). Providers were required to notify their FI/MAC by November 1, 2010, whether they want to elect 100% PPS, or the 4 year Transition.  If a facility failed to notify the FI/MAC by 11/1/2010, then they are automatically in the 4 year transition.  We understand about 87% of providers have elected PPS.  HFS does NOT know when we will se a final form set from CMS, and as such, we don’t know when this new software will be issued to clients.  The Draft can be found at the CMS web site below.  As we get more information, I will post it.

http://www.cms.gov/PaperworkReductionActof1995/PRAL/list.asp?filterType=none&filterByDID=0&sortByDID=2&sortOrder=descending&intNumPerPage=10