Ask For Permission, Not Forgiveness

ask-2341784_1920The expression “It is easier to ask forgiveness than it is to get permission” is attributed to Rear Admiral Grace Murray Hopper. She was a U.S. Naval officer and an early computer programmer who, in 1949, recommended a new programming language be developed using entirely English words. She was told she couldn’t do this because computers didn’t understand English. She did not accept this idea and started work on the process, which later become COBOL, which is the major language used in data processing today.

This tactic is not the one you should use if you are wanting to change the allocation basis on your Medicare cost report. The Centers for Medicare and Medicaid Services (CMS) has a set of standard statistics they have approved for use to allocate expenses on the Medicare cost report. If you decide you want to change the order or use a different statistic, this is permissible but CMS has specific instructions on how and when this is allowed. If you make a change without this request, you are at risk of having your cost report rejected.

Tip #36:

A request to change cost finding methods must be made in writing and submitted to the intermediary 90 days prior to the end of the cost reporting period to which the request for change applies (CMS Pub 15-1, Section 2313).

Further guidance can be found on the CMS website: Provider Reimbursement Manual 15-1

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

“Summertime and the Livin’ is Easy” – Except Unexpected ER Visits

George Gershwin wrote the lyrics “Summertime and the livin’ is easy” in 1934 for the opera “Porgy and Bess.” But summer time generally means extended periods of time spent outdoors which can present ample opportunities to sustain injuries (or hurt others). It is not surprising that Emergency Room visits spike during the summer months. From the first signs of the days getting longer until school is back in session visits to the ER increase by 15 to 27 percent.1 So while the livin’ should be easy, it brings new meaning to the sentiment of enjoying careless summer days when they’re spent in an emergency room.

Hospitals ready for this potential influx of patients by increasing staff, but often it is done through the more flexible route of “on call.” Staff who are on call are paid a flat rate per hour to be available if called to come into work. CMS recognizes the need to have physicians available and in limited circumstances, hospitals can claim this on-call time as allowable expense on the Medicare cost report.

Tip #35:

Time studies are needed to support Emergency Physicians Availability and On-Call Time (Pub. 15-1, §Section 2109).

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.

 

1 ER Visits Peak during the Summer Months, By James Baker, MD, Kaiser Permanente Baldwin Park, California

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 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.

 

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.

 

Provider or Professional? Identifying Allowable Expenses

Advances in clinical care, along with the changing health care delivery environment, have created new opportunities for physicians. Organizations are looking for physicians to advise on issues, such as population health, infection control or electronic health records to name just a few. If your organization has added these things—or is considering it—you need to be cognizant of how those costs will be disclosed on the Medicare cost report.

Physician expense—whether employed or contracted—is considered non-allowable on the Medicare cost report except in very limited circumstances. It is important to identify and differentiate expenses that are “Provider” or “Professional” in nature. CMS defines these as:

  • Provider – services that are administrative in nature and benefit the hospital in general or which represent availability services in a hospital emergency room under specified conditions
  • Professional – services to individual patients

Provider services can be included on the cost report and are subject to further limitation.

Tip #10:

Review your physician contracts and expense to identify all potentially allowable amounts (Pub 15-2, §4108)

Further guidance is available 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.