The Centers for Medicare and Medicaid Services (CMS) released the latest Supplemental Security Income (SSI) percentages for fiscal year (FY) 2019.
Find important information about the publication of percentages below.
Applicable Health Care Entities
CMS published SSI data for the following health care entities:
- Inpatient Prospective Payment System (IPPS) hospitals
- Inpatient rehabilitation facilities (IRFs)
- Long-term care hospitals (LTCHs) that bill Medicare Administrative Contractors (MACs) for Medicare beneficiaries’ services
You can access the FY 2019 SSI percentages electronically on the CMS website, and the following pages focus on each applicable health care entity:
CMS also released a corresponding MLN Matters article–MM12516.
On November 16, 2021, CMS issued a Change Request (CR) providing technical direction to MACs.
The CR states that Medicare Part A “contractors shall update their IPPS, IRF, and LTCH provider specific files prospectively, within 30 days of the implementation date of this CR, using the latest year’s SSI Ratio posted to the CMS website as of the implementation date of this CR, except when explicitly directed otherwise by CMS.”
The guidance takes effect December 17, 2021.
The SSI data files contain:
- The provider number or CMS certification number
- Provider name
- SSI days
- Medicare days
- The ratio of days for patients entitled to Medicare Part A attributable to SSI recipients
Methodology for Calculating FY 2019 SSI Ratios
Unlike past years, two separate SSI ratio data files exist for IPPS hospitals; one for hospitals under the Ninth Circuit’s jurisdiction—Alaska, Arizona, California, Hawaii, Idaho, Montana, Nevada, Oregon, and Washington—and one for all others.
According to the CR, SSI ratios for hospitals in the Ninth Circuit jurisdiction “include only ‘covered days’ in order to reflect the decision of the Ninth Circuit in Empire Health Foundation v. Azar (currently pending before the Supreme Court), in order to preliminarily settle cost reports.
For all other hospitals, the methodology for calculating FY 2019 SSI ratios uses total Medicare days, consistent with our existing regulations.”
Considerations for Hospitals
Hospitals should keep a few factors in mind based on their classification.
FY 2019 SSI ratios will generally apply to Medicare cost reports beginning on or after October 1, 2018 and prior to October 1, 2019 for settlement purposes.
For IPPS hospitals, this updated data will be used to determine their Medicare Disproportionate Share (DSH) adjustment. For those hospitals that don’t share the same fiscal year-end as the federal government—October 1 through September 30—we recommend a review to evaluate if the hospital would benefit from a recalculation.
Current CMS regulations allow a hospital to request a recalculation of its Medicare fraction or SSI ratio based on the hospital’s cost-reporting period if it’s different from the federal fiscal year. Learn more about how to recalculate an SSI percentage here.
IRF hospitals will incorporate the updated percentages into their low-income patient adjustment.
LTCH discharges paid under the short-stay outlier payment adjustment will use updated SSI data.
Protecting SSI Fraction Appeal Rights
We recommend that hospitals not in the Ninth Circuit jurisdiction consult with counsel or their external partner to evaluate the necessity of a protest item for the SSI Fraction to protect the hospital’s appeal rights pertaining to this issue.
When protesting items, it’s important to:
- Remember to follow Medicare rules regarding the identification of an issue. Pursuant to Medicare rules, hospitals must claim an item if the MAC can pay it or protest it if in controversy.
- Provide a calculation detailing the amount in controversy including the accumulation of all applicable supporting documentation.
- Consult appeals counsel to ensure that you properly preserve your rights to reimbursement on this issue.
We’re Here to Help
If you have questions about potential implications of the SSI ratios for your hospital or would like assistance evaluating whether your hospital would benefit from a recalculation, contact your Moss Adams professional.