Pete Harmon's HFS Blog

HFS received a Draft of the SNF T.18, on July 12, 2010.  We commented back to CMS, and changes are being made – most significantly, there are 23 new RUGs instead of 22.  The Draft T.18 removed the option for PPS SNFs to file using the “simplified method” of cost finding (lines 50-52 on S-2 are N/A).  S-7 added lines 45.01 to 45.23 for the new RUGs.  These are to be effective for Services on or after 10/1/2010.  Med Ed and GME for SNF is proposed to be removed.  T.18 is to be effective for FYE after 9/30/2010.  Once we see the Final transmittal, I will update this post.

Transmittal 21 for the Hospital, introduced line 55.30 for Implantable Devices.  There have been questions about whether this is “optional” or “required”.  The Federal Register of 8/27/2009, page 43781, says this cost center MUST be used in the 2552-96, for FY Begin 5/1/2009 and after; and for the 2552-10, line 72 MUST be used for FY Begin 5/1/2010 (the effective date of the 2552-10).  Therefore, the costs and charges for Implantable Devices must be accounted for separately from Medical Supplies.

HFS received a Draft of T.22 for the Hospital on 8/13/2010.  We commented back to CMS about changes needed and received the T.22 Test Case, so we can get CMS approval for our Version 22 software, on 8/23/2010.  We are awaiting CMS approval.

T.22 changed from our original understanding, to have 23 new RUGs, instead of 22.  The TOPS extension for small, rural, and all SCH, necessitated the addition of column 2, to S-2 line 21.07.  SCH MUST answer this “Y” to get the TOPS calculation, for the period 1/1/2010 to 12/31/2010.  Charges will also need to be split on W/S D part V, columns 5.01 and 5.03, as well as split payments on E part B, line 1.02.  W/S E part A line 24.97 was designated (hard coded) for the Health Care and Education Reconciliation Act (HCERA) Payments, which are one time payments in Federal Fiscal Year 2011 and 2012.  They are recorded on E-1 as “interim payments”, and also on E part A line 24.97.

On July 8, 2010, CMS rescinded the J-15 (Ohio and KY) award to Highmark, and awarded it to CIGNA, due to a protest.  We now hear this has been protested by Highmark and Cahaba.  When the “dust settles”, I’ll let you know!

CMS has indicated the new 2540-10 for SNFs, will be effective for FY Begin 12/1/2010 and after.  We have not seen the “Final” forms yet, so when we do, I will update this post.  We know the “final” we have seen to date, must change for the addition of 22 new RUGs, effective for Services on or after 10/1/2010.

CMS must issue Transmittal 22 for the 2552-96, to incorporate changes required by the Patient Protection and Affordable Care Act (ACA).  The TOPS extension for small rural hospitals, and Sole Community hospitals, through 12/31/2010 is the most significant change.  CMS is also changing the “effective date” for the use of line 29, on S-3 part I, for the Labor/Delivery Days, which need to be included in the DSH calculation, per the CMS 1498R Ruling.  FI/MAC will be able to use line 29 for FY prior to 10/1/2009 (currently line 29 can only be used for FY Begin 10/1/2009 and after).  There are also 22 new RUGs for hospital based SNFs.  These are effective for Services on or after 10/1/2010.  When we receive T.22, I will post the details.

The CMS is currently transitioning the Jurisdiction 1 providers out of the legacy WPS workload and expects to complete the transition no later than April 2010.  The balance of legacy Mutual of Omaha providers will remain in workload number 52280 until further notice.

CMS will not transition providers from legacy fiscal intermediaries and carriers to the following MACs until procurement corrective action on the respective contract awards has concluded.

The legacy fiscal intermediaries and carriers will continue to service the providers in those workloads until further notice. 

In my earlier Posts (and our web site, www.hfssoft.com), I had FY Begin and FYE 10/1/2009, for the effective date of T.17.  This is to clarify that the SNF T.17 is effective for FY END 10/1/2009 and after (i.e. MUST be used for this FYE).  Also, CMS rescinded the change to S-2 line 20, to require an answer of F/L/N for a Full, Low, or No Medicare Utilization report.  S-2 line 20 reverts back to T.16, where you ONLY complete it with an L or N, for Low/No utilization.  If it is a Full report, line 20 is left Blank.

HFS recently received approvals for the Hospital 2552-96, Transmittal 21 (our version 21.0.119.0), which we posted 3/12/2010; SNF 2540-96, Transmittal 17 (our version 17.0.119.0); HHA 1728-94, Transmittal 14/15 (our version 15.0.119.0); and RHC/FQHC 222-92, Transmittal 8/9 (our version 9.0.119.0).  All of these MUST be used for cost reports with FYE on or after 10/1/2009.  We expect to post the SNF, HHA, and RHC/FQHC updates this week (week of 3/15/2010).  CMS was late with these approvals, so if you have begun your report on an older version, you simply need to do a Check for Updates (under Help in our software), and get the new version(s).  You must use these new version to file reports with FYE of 10/1/2009 and after.  See my earlier posts for the detailed changes in these Transmittals.