In this episode, we’re pleased to welcome back Christina Brown, BESLER’s Director of Reimbursement, to give us a glimpse into the next Reimbursement Best Practices series healthcare finance webinar, Reimbursement Updates, on Wednesday, June 7th, 2023, at 1 PM ET.Learn how to listen to The Hospital Finance Podcast® on your mobile device.
Highlights of this episode include:
- Reimbursement updates
- Insight on what the webinar will be focusing on
- Transmittal 18
- Supplemental exhibits
- FY 2024 IPPS proposed rule
Kelly Wisness: Hi, this is Kelly Wisness. Welcome back to the award-winning Hospital Finance Podcast. We’re pleased to welcome back Christina Brown, BESLER’s Director of Reimbursement. In this episode, Christina will give us a glimpse into the upcoming BESLER webinar, the next in our Reimbursement Best Practices series, Reimbursement Updates, that we’re hosting on Wednesday, June 7th, 2023, at 1 PM Eastern Time. Thank you for joining us today, Christina.
Christina Brown: Thank you, Kelly. It’s always a pleasure to be here.
Kelly: Well, let’s go ahead and jump in today. So can you touch on the reimbursement updates that will be included in your upcoming webinar?
Christina: Oh, sure thing. So, during the webinar, I’ll be addressing some pertinent releases and updates from about the past six months that will impact the hospital costs reports. During that time, over the past about six months, there have been a few releases. And I will be touching on some more than others. The first topic, as it has the most immediate impact, will be the updates as a result of Transmittal 18. Some of the other updates, if you’ve been following the CMS releases, are the subsequent releases of Transmittal 19 and Transmittal 20. And both of those actually occurred within a month of each other. And also during this time, the FY 2024 IPPS proposed rule was also released. So, I’m going to be providing a high-level overview of the proposed rule as it impacts the hospital cost report, as well.
Kelly: Yeah, I know there’s been quite a bit released over a short period of time. Can you offer a little insight as to what area you might be focusing on the most?
Christina: Sure. Yeah. And that’s actually a very good point. We’ll be touching on all of those areas previously mentioned. There will be a great deal of focus on Transmittal 18 as that transmittal had the most updates of significance. And while we have touched on some of the exhibits released with Transmittal 18 in previous webinars, and we are actually probably going to likely be touching on them again in the future, I do feel it is important to go into more detail and discuss them here all in one place. In addition to the transmittals, I will also talk about the FY 2024 IPPS proposed rule. Again, I will touch on this briefly. As we all know, the final rule will be released probably sometime around August. And while the proposed rule does give us a little insight as to what is to come, anyone who has been in reimbursement for any length of time and keeps up with the rulemaking understands that there is typically some variability in the proposed rule and the final rule. And I’m just going to note here that BESLER will actually offer another webinar once that final rule is released.
Kelly: Great. And so can you elaborate a little bit more on the Transmittal 18 and what types of things you will be going over in more detail?
Christina: Sure. Yes, I’d be happy to. So, there were many changes to the 2552-10 form for the addition of CHART hospital verbiage. And if you’re unfamiliar with CHART, it is the Community Health Access and Role Transformation model providers. And there are actually very few of those nationwide. But most notably were the additions of S-10 Part 2 Worksheet D-6 and several support exhibit formats that will now be required upon submission. And I will discuss both of these worksheets as well as go over all of the exhibits in greater detail in the webinar.
Kelly: Fantastic. I know there’s been much discussion over the supplemental exhibits that will be required for cost reports beginning on or after October 1st, 2023. Would you give us an overview of the exhibits you will be going over in the webinar?
Christina: Yes, you’re absolutely right. And I’m actually going to spend a great deal of time going over each of these exhibits in great detail. I anticipate that CMS is putting these exhibits into place in order to gain more control over the reporting. And we have seen many different audits, and with that, have seen much variation over the audit requests. And we actually have updated our exhibit formats for our current clients based upon the audit entity. And so it was no surprise that CMS put something out that was more standardized. And actually, we did see some exhibits in Transmittal 17, but they pulled them back. So, we weren’t surprised to see them in Transmittal 18 when these were released. And just given the evolving focus and reimbursement amounts in the DSH and uncompensated care areas, again, I’m not surprised with the introduction of Exhibits 3A for DSH and 3B and 3C for charity and bad debt on Worksheet S-10. And in addition to 3A, 3B, and 3C, Medicare also introduced Exhibit 2A, which is to be utilized for Medicare bad debts. And that actually does require much more information than what Medicare had previously put in the suggested what they were calling Exhibit 2.
Kelly: Great. And so can you provide a preview of what you will be discussing in regards to the FY 2024 IPPS proposed rule?
Christina: Sure. So, I’ll start by mentioning that comments to the proposed rule are due by June 9th, 2023. And as for the updates, as with every rule, CMS proposed base rate updates. And in the proposed rule, the net increase of 2.8%, which is actually lower than the 3.8% increase for federal fiscal year 2023– the 2.8% results from a 3% increase to the market basket estimate. And the offset of 0.2% is for the productivity adjustment. And I should also mention that CMS proposes that rates for LTAC payments would also decrease by 2.5% when compared to federal fiscal year 2023. As expected, CMS proposed a reduction in the overall uncompensated care poll. And they’re proposing a 6.7 billion. And that was actually a $6.8 billion in FY23. And there’s also a proposal to use three audited years of data. And those years would be for your fiscal years 2018, 2019, and 2020. And those three would be used to calculate Factor 3 from the uncompensated care poll distribution. Previously, I believe they were using two audited years or the most recent audit year. It’s changed. It’s been evolving over time. So, we weren’t surprised to see this in the proposal, because they do want to go to this rolling average. There were also several proposed updates to healthy equity and quality measures as well as many other areas. But I really won’t be addressing those in the webinar as I will be focusing more on the items specifically related to cost reporting. So, I do hope that you will join me for the webinar.
Kelly: Sounds great. Looking forward to learning more about that. Thank you so much for joining us today, Christina, and for sharing this glimpse into your upcoming webinar on Reimbursement Updates that you’re presenting live on June 7th, 2023, 1 PM Eastern Time. And as a bonus, you can earn CPE. Thanks again, Christina.
Christina: Thanks so much.
Kelly: And thank you all for joining us for this episode of The Hospital Finance Podcast. Until next time…
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