The Centers for Medicare & Medicaid Services (CMS) on Sept. 29 revised the worksheet S-10 of the Medicare cost report and the accompanying instructions. CMS also extended the deadline to Oct. 31 for hospitals to submit worksheet S-10 revisions for FYs 2014 and 2015.

Hospitals use the worksheet S-10 to submit uncompensated care data to CMS; the agency will begin using the worksheet to calculate Medicare disproportionate share hospital (DSH) payments in fiscal year (FY) 2018. It is important for association members to ensure they accurately capture all uncompensated care costs as defined in the revised instructions.

Details of Changes

The changes to the worksheet S-10 are primarily limited to the lines for charity care and bad debt, including:

  • a revised definition of charity care to include uninsured discounts, namely discounts for uninsured patients who meet the hospital’s charity care or financial assistance policy (FAP);
  • modification of line 20 (charity care charges) and the associated instructions to include uninsured discounts;
  • revised instructions for line 26 (total facility bad debt expense) to clarify that the amount reported is net of recoveries;
  • addition of a new line, 27.01, for calculating allowable Medicare bad debt expense;
  • categorization of lines 17 to 19 under “grants, donations and total unreimbursed cost for Medicaid, CHIP, and state/local indigent care.” These lines previously were listed under “uncompensated care” and America’s Essential Hospitals asked the agency to clarify. Moving these lines under a separate classification shows these data are not used for uncompensated care purposes; and
  • clarification of instructions regarding when the hospital cost-to-charge ratio (CCR) is applied to charity care and bad debt amounts, including that:
    • deductibles and coinsurance amounts for insured patients written off as charity care on column 2 of line 20 are not multiplied by the CCR (other charity care amounts, such as amounts written off for the uninsured, should be multiplied by the CCR);
    • in column 2 of line 21, hospitals should multiply the noncovered charges for Medicaid, state, or local indigent care program patients who exceed a length-of-stay limitation by the CCR (hospitals can include these charges on line 20 if they are covered by the hospital’s charity care policy or FAP);
    • hospitals should not multiply non-reimbursed Medicare bad debts by the CCR; and
    • hospitals should multiply non-Medicare bad debts by the CCR.

CMS in an article describes these changes and provides multiple examples of how to calculate charity care and bad debt. Members should review the the revised S-10 instructions and the revised worksheet S-10 (both include revisions in red text).

Contact Director of Policy Erin O’Malley at eomalley@essentialhospitals.org or 202.585.0127 with questions.