Are you prepared for uncompensated care S-10 audits?

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As part of the changing calculation of the Disproportionate Share Hospital (DSH) payment adjustment, hospitals in the past several years have had to report, among other things, the amount of uncompensated and charity care provided by the hospital on Worksheet S-10 of their cost reports. This information will be incorporated into the calculation of the new Hospital-Specific Factor 3 for the DSH uncompensated care payment (DSH UCP). At the direction of the Centers for Medicare and Medicaid Services (CMS), the Medicare Administrative Contractors (MACs) have recently been sending out Additional Documentation Requests (essentially desk audit notifications) regarding the information claimed by hospitals on Worksheet S-10.

The data requests are often voluminous, requiring hospital policies for charity care and financial assistance, narrative descriptions of hospital data query procedures used to gather data for reporting on Worksheet S-10, detailed charge and payment listings, and explanations for year-to-year variations in both Worksheet S-10 data and the hospital’s reported financials. In addition, the time frame for responding to these requests is often quite short.

Because the data in question will affect the amount of the hospital’s DSH payment adjustment going forward, it is important to ensure that accurate information is being claimed on Worksheet S-10 on each cost report and provided to and verified by the auditors.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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