Following a second update in less than a year to the instructions for completing Worksheet S-10, CMS has now also provided a further extension for providers to file an initial or revised Worksheet S-10, which is used by providers to report cost data on uncompensated and indigent care. The extension moves the deadline from October 1, 2017 to January 2, 2018 and applies to all inpatient prospective payment system (IPPS) hospitals.

Revised instructions for Worksheet S-10 were issued by CMS on November 18, 2016, via Transmittal 10, and again on September 29, 2017 via Transmittal 11. Transmittal 11, for example,  included new language stating that “discounts given to uninsured patients that meet the hospital’s . . . uninsured discount policy may be used in the calculation of the uncompensated care payment” (emphasis added). A detailed explanation of the revised instructions can be found by clicking here.

The revised instructions were issued against the backdrop of CMS’ announcement in the FY 2018 IPPS rulemaking that the agency will use Worksheet S-10 data to determine how the uncompensated care component of the disproportionate share hospital (DSH) payment will be distributed among eligible hospitals. Specifically, CMS is phasing out the use of Medicaid and Medicare/Supplemental Security Income days and will begin incorporating data from Worksheet S-10 to calculate the third of three factors it uses to determine how DSH payments are distributed amongst eligible hospitals.

While hospitals are not required to submit amended Worksheet S-10s, they may choose to resubmit if they have additional data corresponding to the new instructions. Since Worksheet S-10 data from the FY 2014 and 2015 cost reports will play a significant role in the hospital’s future allocation of DSH payments, hospitals should give serious thought to the potential benefits of amending their cost reports consistent with the new instructions.

If an eligible hospital expects to encounter difficulty in meeting the extended deadline of January 2, 2018, the hospital may reach out to CMS via its Medicare Administrative Contractor (MAC) to request that CMS consider additional time.