From Maps to Apps: Advertising Public Info on Hospital May Be an Allowable Cost

Many years ago, the only real way to find your way from one city to another was to use a paper road map that had to be unfolded (and, of course, never folded back up the original way).

Today there are many options to help you navigate from websites such as MapQuest and Google Maps, stand-alone GPS units, and smart phone apps such as Waze or Co-pilot.

A similar situations exists for finding a hospital; many years ago you just had to look for the road sign and easily locate the nearest facility.

Today there are many options that publicize and promote hospitals which not only tell you where to find one, but what services they offer, the operating hours, physicians on staff, and many other things. Nowadays many ads go one step further and seek to differentiate it from other hospitals by citing statistics of quality, patient satisfaction, faster wait times, etc.

Tip #29:

Advertising that can be characterized as public information may be considered an allowable cost (CMS Pub 15-1, Section 2136).

Further guidance can be found on the Centers for Medicare and Medicaid Services (CMS) website:

Provider Reimbursement Manual 15-1

Questions? Please contact Marie White at 612.253.6546 or mewhite@eidebailly.com.

 

The Effect of Shrinking Rural America on Medicare Productivity Standards

michael-smithIn 1900, some 40 percent of the population worked in agriculture, a century later, only two percent did.1 Manufacturing jobs in most small towns began to disappear by the 1980s. Rural America, more than much of the rest of the country, is the victim of productivity gains. And in rural America, fewer other opportunities materialize to replace the jobs the machines take.

Our transition from rural to metropolitan has been rapid. At the beginning of this century, 60 percent of the people lived on farms or in villages. Today, just 19 percent of Americans live in areas the Census department classifies as rural, down from 44 percent in 1930.

This week’s tip goes hand-in-hand with our previous posting (please see tip #22) on the importance of accurately calculating your physician and mid-level FTEs for Rural Health Clinics (RHCs). The RHCs could receive enhanced reimbursement from Medicare and Medicaid, but this is dependent upon FTE counts and the relationship to productivity thresholds.

In some situations, a RHC has the necessary physician or mid-level to provide care, but due to declining populations, economic conditions or a combination of these, insufficient patient volumes exist to prevent the RHC from being impacted by the thresholds.

Tip #28:

The Medicare Administrative Contractor that processes Part A and Medicare Part B claims has the discretion to make an exception to the productivity standards based on individual circumstances (Chapter 13, Section 80.4).

Further guidance can be found on the Centers for Medicare and Medicaid Services (CMS) website:

Medicare Benefit Policy Manual RHC/FQHC

Questions? Please contact Michael Smith at 701.239.8635 or msmith@eidebailly.com.

1“The Graying of Rural America,” by Alana Semuels, The Atlantic

The Constitution and CMS Regulations as Foundations: Interpreting Living Documents

US Constitution and FlagIt is generally accepted that the Constitution of the United States is known as a “living document” because its authors intended it to be adapted by future generations. In the past 200 years, the Constitution has been amended 27 times. Additional amendments may be needed in the future. For example, advances in technology may change the way we communicate. Someday, we may be able to vote from our own homes.

The federal regulations that govern the Medicare program can be similarly ascribed as a living document. The regulations themselves don’t change very often, but The Department of Health and Human Services, as well as the Centers for Medicare and Medicaid Services are always interpreting the regulations and issuing guidance in how they apply to health care providers.

Unfortunately, there is no crystal ball to see the future in health care. Therefore, it is often up to the individual hospital to understand and interpret the rules. This is especially true in the evaluation of new services and programs a hospital may choose to offer to its community.

In reviewing a new service, a hospital should use the regulations to provide a framework in deciding whether the new cost center is allowable or non-reimbursable.

Tip #27:

Costs of items or services that bear no relationship to care of hospital patients should be disclosed as non-reimbursable cost centers (Pub. 15-1, section 2328)

Further guidance can be found on the Centers for Medicare and Medicaid Services (CMS) website:

Provider Reimbursement Manual 15-1

Questions? Please contact Marie White at 612.253.6546 or mewhite@eidebailly.com.

 

Right Place at the Right Time

Flight attendant serving mealTaking an airplane flight involves getting you from one place to another, but where you sit and how much you pay widely varies these days. Some airlines offer first class, business class and coach, while others have only one kind of seating. The in-flight services you receive also vary. First class often receives complimentary drinks, food and other perks that the other sections do not. The overall result is you generally get what you pay for.

In receiving care at a hospital, one sometimes runs into a similar experience. Where you are treated influences the care you receive. If a patient presents in a hospital emergency room (E/R) and needs to have IV fluids infused over four hours, the cost of providing that service is different than if a patient had an IV fluid infusion in an inpatient room (I/P). In the E/R, you might be on a gurney with a curtain drawn around and a nurse gives you the infusion while also looking after four or five other patients. In an I/P room, you get a nice bed in a private room and the nurse may only have one to two other patients.

When the service gets billed to Medicare, there is no difference in how you get paid. But for some hospitals it is important to properly identify the costs on the Medicare cost report.

On the Medicare cost report, the B-2 post stepdown adjustment is designed to help CMS appropriately partition and understand the cost of providing care at a hospital, based on the acuity of the service provided, rather than the location.

Tip #26:

Use a B-2 adjustment when outpatient ancillary services are provided in an inpatient area. (Pub. 15-2, §Section 4022)

Further guidance can be found on the Centers for Medicare and Medicaid Services (CMS) website.

Questions? Please contact Marie White at 612.253.6546 or mewhite@eidebailly.com.

 

Fee schedule vs. a la carte hospital bills

When dining, one consideration in choosing a restaurant is the concept of “a la carte” dining, which means “from the menu.” When you order a la carte you are ordering individual items, rather than a complete meal. The opposite of a la carte is a “table d’hôte,” which is a meal served at a fixed price. Cheerful couple with menu in a restaurant making orderThe total cost of a meal consisting of several la carte items tends to be much more expensive than that of a fixed price full meal.

A similar concept exists in health care. Someone might receive care at a hospital and then gets an itemized bill for each service provided. This is a la carte care and anyone who has gotten a hospital bill knows this tends to be very expensive. But health care has its own version of table d’hôte called the fee schedule. Fee schedules exist for such things as laboratory, therapies, and ambulance services to name just a few. And just like fine dining, fee schedule health care services are a fixed price.

When a Medicare beneficiary does not pay their responsibility for fee schedule amounts, Medicare has taken the position that since the items are a fixed price, there is no unrecovered cost attributable to uncollectible deductible and coinsurance arising from covered services.

Tip #25:

Bad Debts that arise under a fee schedule are not reimbursable on the Medicare cost report.

Guidance can be found on the Centers for Medicare and Medicaid Services (CMS) website. In addition, each MAC may have supplemental guidance on this issue.

Medicare Intermediary Manual – Transmittal 1872

Questions? Please contact Marie White at 612.253.6546 or mewhite@eidebailly.com.

 

New Year’s Uber Rides and SNF Contracted Personnel

Man Using the Uber Taxi App on Iphone in NYC

This week’s tip is for the Skilled Nursing Facility (SNF) folks, but also has relevance to hospitals.

Each New Year’s Eve, there is demand for taxis—and now Uber drivers—to safely transport revellers home .This year, it was reported that Uber prices surged by nearly 10X during peak times (between midnight and 3:00 a.m.) following celebrations.

A similar situation exists for health care providers and the demand for their services. With the current strong economy, it has become a huge challenge for SNFs and hospitals to find personnel to provide necessary services to residents and patients. People have their choice of employer and locations in this competitive environment. Health care providers often have to resort to using contract nurses and other professionals who may have to travel several hours to a facility. In addition to an hourly wage, the facility may have to pay mileage, hotel and other travel costs to the contractor or an agency.

CMS recognizes that contracted personnel is a necessary and allowable expense, but there are further rules that govern what can be included for wage index computations (see Tips# 4 & 8 for further insight on wage index).

Tip #24:

SNF contracted personnel costs should not include miscellaneous items, such as travel or supplies expense. (Pub. 15-2, §4105.1).

Further guidance can be found on the Centers for Medicare and Medicaid Services (CMS) website:

Provider Reimbursement Manual 15-2

Questions? Please contact Marie White at 612.253.6546 or mewhite@eidebailly.com.

 

Porsche vs. Honda: Spend Less to Get More!

When it comes to purchasing a car, most people budget for features they want in a vehicle, such as automatic transmission, air bags and power door locks/windows. There might be additional upgrades available, but they aren’t necessary for you to get around. As long as the vehicle enables you to get from point A to B, you’re good to go. A similar situation exists for Medicare hospitals in regards to nursing personnel. CMS wants you to employ the appropriate level of nursing staff for the care to be provided.

Every three years, a Prospective Payment Hospital (PPS) hospital is required to submit a survey that identifies the wages and hours of its employees by certain job categories. CMS then uses this data to come up with a factor that either increases or decreases the wage index. An increase can occur if a hospital uses lower wage LPNs and aides, rather than RNs. CMS does this to equalize the wages paid as a hospital should not be “rewarded” for using all RNs when a lower professional level is appropriate.

The survey is due to your MAC by July 1, 2017.

Tip #23:

Start reviewing your wages and hours by job category early to ensure you have the most accurate data to submit for Occupational Mix.

Further guidance should be available on the website of the Medicare Administrative Contractor (MAC) you are assigned to.

Questions? Please contact Marie White at 612.253.6546 or mewhite@eidebailly.com.