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.

 

Documentation: “If a Tree Falls . . .”

“If a tree falls in a forest and no one is around to hear it, does it make a sound?”

Marie White

Marie White

One of the most challenging issues in health care is documentation. Like the above quote, it’s become somewhat of a cliché, but nevertheless it’s true: if you didn’t document it, you didn’t do it or it didn’t happen. This mantra is equally important for services you provide to patients, as well as services you purchase from others.

The hospital must ensure that supporting documentation for both salaries and hours are based on actual data maintained in a form that permits validation by the contractor. The use of estimates for these amounts is unacceptable for the wage index.

Tip #5:

When reporting contract labor for wage index, ensure you have hours to match expense (Pub 15-2, §4005.2)

Further guidance on the types of hours that should be included on Worksheet S-3, part II 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.

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.

 

Worksheet S-2: Know Your Facility

Marie White

Marie White

In the words of the famous philosopher Aristotle, “The more you know, the more you know you don’t know.” This quote couldn’t be more appropriate for cost reports.

The Centers for Medicare and Medicaid Services (CMS) generally publishes regulations and notices on the fourth Friday of each month. In 2015, this amounted to more than 200 notices, so keeping up is somewhat of a challenge!

One thing that may make it easier to stay current with the changes is a better understanding of your own facility. The cost report includes a Worksheet S-2 that has various questions about your facility and if you can develop an understanding of these, it could help you know when a newly published regulation has a potential impact on you.

Tip #2:

Confirm all S-2 questions are answered properly (Pub 15-2, §4004)

Worksheet S-2 includes Part I (171 questions) and Part II (43 questions) and the corresponding instructions encompass twenty-seven pages; the entire instructions are 500+ pages so some “light reading” when you have some free time. Separate instructions exist for SNFs (Chapter 41) and Hospice (Chapter 43).

The instructions are available on the CMS website:

Provider Reimbursement Manual 15-2

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