This article is up-to-date as of June 30, 2020. We'll continue to revise it as new information becomes available.
The Centers for Medicare and Medicaid (CMS) extended the filing deadlines for certain Medicare cost report fiscal year ends (FYEs) in the wake of COVID-19 disruption.
Details about the extensions, as well as important considerations for providers, are below.
Affected Fiscal Year-Ends
CMS has authorized filing delays for the following FYE dates:
- October 31, 2019
- November 30, 2019
- Revised—December 31, 2019
- New—January 31, 2020
- New—February 29, 2020
The revised deadline for the October 31, 2019, and November 30, 2019, FYEs was June 30, 2020. The filing deadlines were originally March 31, 2020, and April 30, 2020, respectively.
December 31, 2019, FYEs were originally delayed from May 31, 2020, until July 31, 2020. An additional extension was granted until August 31, 2020.
January 31, 2020, FYEs were delayed from June 30, 2020, until August 31, 2020; while February 29, 2020, FYEs were delayed from July 31, 2020, until September 30, 2020.
Since March 2020, CMS issued several waivers and flexibilities for health care providers. They issued provider specific fact sheets containing the revised deadlines.
Medicare Administrative Contractors (MACs) were made aware of the filing extensions and should have information on their websites.
Considerations for Providers
Prior to submitting cost reports, providers should address several areas of filing information.
CMS released the latest Supplemental Security Income (SSI) percentages for fiscal year (FY) 2018 that should be used when filing affected Medicare cost reports.
Supporting Documentation Requirements
The FY 2019 Inpatient Prospective Payment System (IPPS) Final Rule changed documentation requirements when submitting cost reports for periods beginning on or after October 1, 2018.
Medicare Disproportionate Share Hospitals (DSH)
As part of the cost report filing, DSH-qualifying hospitals must now include a detailed listing of its Medicaid eligible days that correspond to the Medicaid eligible days claimed in the cost report.
In addition, hospitals need to provide patient detailed charity care data tied to the hospital’s actual filings on the Worksheet S-10.
CMS provided examples of the information needed to support S-10 data, such as:
- Patient name
- Dates of service
- Amount of charity care and uninsured discounts given, or both, that corresponds to the amount claimed in the hospital’s cost report
S-10 Summary Reports Insufficient
If your hospital has historically used summary reports to report S-10 values, those will no longer suffice under the requirement.If your hospital historically used summary reports to report S-10 values, those will no longer suffice under the requirement.
Additionally, summary reports have the potential to vary greatly from the actual detail of charity write-offs that occurred during the fiscal year and won’t meet MAC S-10 audit requirements.
Additional Required Data
As reminders, providers that claim reimbursement for Medicare Bad Debt need to continue to submit a detailed listing tying to the amount claimed in the cost report.
Teaching hospitals will need to provide Intern and Resident Information System (IRIS) data.
Additionally, home office cost allocation statements also need to be submitted as supporting documentation for applicable providers.
All of these requirements affect the acceptability of the cost report. Without the applicable supporting documentation, a cost report will be deemed unacceptable and the report will be rejected.
We’re Here to Help
If you have questions about the cost report filing deadlines or supporting documentation requirements for your hospital, contact your Moss Adams professional.
Note on COVID-19
During this unparalleled time, we’re closely monitoring the COVID-19 situation as it evolves so we can provide up-to-date guidance and support to help you combat uncertainty. For regulatory updates, strategies to help cope with subsequent risk, and possible steps to bolster your workforce and organization, please see the following resources: