To obtain the provider reimbursement you’re entitled, it’s critical for hospitals to correctly file Medicare cost report Worksheet S-10 now that a portion of provider reimbursement is distributed to hospitals based on their percentage of reported uncompensated care costs. Doing so effectively, however, can be an extensive process.
Our thorough Worksheet S-10 Uncompensated Care Compliance Program can help you accumulate and report required data on Worksheet S-10.
We’ll work with you to help ensure your submissions meet the provisions of Worksheet S-10 instructions and will be in accordance with your hospital’s charity or financial assistance policies. Additionally, we can fully support you through any audit. Our dedicated S-10 team has helped more than 230 hospitals nationwide collectively complete more than 800 S-10 reviews and has supported our hospital clients through more than 40 S-10 audits conducted by all but one MAC.
How the Process Works
Our comprehensive S-10 compliance program includes a thorough review and analysis of your:
- Financial assistance policy (FAP)
- Bad debt policy
- Self-pay discount policy
- Policies compared to the program reporting requirements for Worksheet S-10
Our extensive review of FAPs helps ensure compliance with S-10 instructions, 501(r), and Topic 606 requirements. If elected, we can develop and draft a template FAP for the hospital’s use.
Concurrently, we build Worksheet S‐10 data from the ground up, obtaining all inpatient and outpatient data at the transaction level. We mine the data using a software solution while also utilizing a hands-on account level review to help make sure your report is filed correctly.
We accomplish this by:
- Mining data through software solutions combined with a hands‐on account level review
- Mapping all accounts back to transaction codes and FAPs
- Segregating insured versus uninsured detail
- Properly reporting copays, deductibles, and non‐covered services
- Identifying professional fees that can’t be included in reimbursements
- Sampling accounts to help support be provided per FAP requirements
In addition, we’ll review the process of recording the applicable write-off transactions through your patient accounting and general ledger systems to determine compliance with established policies and procedures. You’ll receive a detailed analysis comparing and contrasting your policies to program reporting requirements for Worksheet S-10.
You’ll also be provided future recommendations, including identifying areas inconsistent with Medicare program regulations and instructions for your hospital to maintain ongoing compliance.
Background on Worksheet S-10 Uncompensated Care
Provider reimbursement is now distributed to hospitals based on their percentage of uncompensated care reported on Medicare cost report Worksheet S-10. Center for Medicare and Medicaid Services (CMS) changed the distribution of reimbursement from a low-income model to an uncompensated care model. Hospitals will continue to receive 25% of their empirically-justified DSH reimbursement under the traditional formula.
For fiscal year (FY) 2018, CMS distributed the remaining 75% uncompensated care pool—75% less adjustments for the change in uninsured—based on a factor of the hospitals’ low-income days, including supplemental security income and Medicaid days, and Worksheet S-10 uncompensated care costs, per Line 30.
For FY 2019, CMS continued this methodology and used Worksheet S-10 for two-thirds of Factor 3 to distribute uncompensated care payments. Based upon the FY 2020 proposed rule, CMS will distribute the uncompensated care pool using only one-year of data solely from cost report Worksheet S-10.
Worksheet S-10 is also being used by some states, including Texas and New Mexico, to determine Uncompensated Care pool and distribute Medicaid supplemental waiver payments.