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

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.

 

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.

Miles per Dollar and RHC FTEs

People running Outdoor activity Healthy lifestyleWhat if someone offered you $10,000 to walk 10 miles; the next person is offered $10,000 and only has to walk five miles? Then another person is offered $10,000 for one mile. Your 10-mile deal seems pretty unfair now, doesn’t it? Why should someone walk less and get paid the same? Productivity standards in health care exist to prevent this type of unfairness. A minimum level of effort is established to correspond with the dollars to be paid.

The Rural Health Clinic (RHC) program is intended to increase access to primary care services for Medicaid and Medicare patients in rural communities. A RHC is a clinic located in a rural, medically under-served area in the United States as defined by the Health Resources and Services Administration.

RHCs are staffed by a combination of physicians, nurse practitioners (NP), physician assistants (PA), and certified nurse midwives (CNM). Minimum staffing levels are required based on full-time equivalents or FTEs (which are the “miles”).

The computation of the FTE for each nurse practitioner, physician assistant, or certified nurse midwife can be confusing as only the time spent seeing patients or scheduled to see patients should be counted. The same challenge exists in computing the Physician FTE.

Tip #22:
Ensure RHC FTEs are properly computed (Chapter 13, §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 Marie White at 612.253.6546 or mewhite@eidebailly.com.

Forgetta ‘bout it: Free Agents and FICA

QuarterbackFall time is synonymous with football. Just as in football, health care has it’s own brand of free agents. And just as in football, compensation and other related activities are treated differently in health care. Find out how you can say “forgetta ‘bout it” to private practice physicians and FICA and other employment-related taxes on your cost report.

Per the 2015 Medscape Physician Compensation Report, 63 percent of physicians are employed, with less than a third (32 percent) in private practice. This follows the trend reported by a major physician recruiter, which revealed a hospital employment rate of 11 percent in 2004, rising to 64 percent in 2014. This shift is occurring due to the increasingly uncertain environment and burdensome administrative requirements in private practice.

Employment of physicians is challenging for many reasons, including how it’s reported on Medicare cost report. Employed physicians’ compensation must be disclosed on Worksheet A-8-2 as either provider or professional component (see Medicare Cost Report Talk blog tip #10 posted on June 13).

Employment-related taxes, such as FICA, Workers’ Compensation and Unemployment Compensation, which are paid by a hospital on behalf of an employed physician, are considered business expenses of the hospital and not fringe benefits. Thus, the amount for A-8-2 excludes these dollars.

Tip #19:

For Worksheet A-8-2, exclude FICA from the benefits add-on to physician salary (Pub. 15-1, Section 2122.3).

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.

Payments Can Make or Break You

Marie White

Marie White

“The difference between something good and something great is attention to detail.” Charles R. Swindoll

Medicare pays Acute Care Hospitals for Part A and B services via submitted claims; inpatient is paid under Diagnosis Related Groups (DRGs) and outpatient is Ambulatory Payment Classifications (APCs). Some hospitals can receive added payments for things such as medical education, bad debts, uncompensated care, and others. Medicare will often make additional payments for these items on a periodic basis.

When completing the cost report, it is extremely important to identify the payments you have received on individual claims—these are on a Provider Statistical and Reimbursement (PS&R) report. You also need to include any additional payments you have received for other items. Over- or understating one of these could have a significant impact on the due to/from settlement.

Tip #3:

Confirm and include all pass through and lump-sum payments (Pub 15-2, §4031)

The cost report must include all interim Medicare payments paid on individual bills, pass through payments for services rendered in this cost reporting period.

Further guidance on the types of payments to be disclosed on Worksheet E-1 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.