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CMS Releases Q&A Document on Worksheet S-10

The Centers for Medicare & Medicaid Services (CMS) on Dec. 27 released a Questions and Answers (Q&A) document providing guidance on worksheet S-10 of the Medicare cost report.

Hospitals use the worksheet S-10 to report uncompensated care data to CMS. The agency began using the worksheet to calculate Medicare disproportionate share hospital (DSH) payments in fiscal year (FY) 2018.

The new guidance follows a set of revisions CMS made to the worksheet in September 2017. In response to requests for clarity following the FY 2018 Inpatient Prospective Payment System (IPPS) final rule, the Q&A:

  • defines courtesy discounts, which are not included as uncompensated care, and clarifies the difference between self-pay/uninsured discounts and courtesy discounts;
  • notes that a hospital’s written charity care or financial assistance policy (FAP) must explicitly include self-pay discounts to be written off as charity care, even if state law requires self-pay discounts;
  • defines when a bad debt is considered to be “written off”;
  • clarifies when unpaid coinsurance and deductible amounts can be reported as charity care  instead of bad debt;
  • discusses how to treat unpaid coinsurance and deductible amounts for Medicare Advantage patients;
  • states that charges for Medicaid noncovered services must be specified in the charity care policy or FAP;
  • details the procedure for revising worksheet S-10 of cost reports that already have been settled (through a request for reopening to the Medicare administrative contractor); and
  • reiterates that revisions to FY 2014 and FY 2015 cost reports are limited to lines 20, 22, 25, and 26 of worksheet S-10.

Hospitals should review the guidance to ensure their written charity care and FAPs are consistent with CMS’ policy.

Contact Director of Policy Erin O’Malley at or 202.585.0127 with questions.


About the Author

Rachel Schwartz is a former policy associate at America's Essential Hospitals.

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