The Centers for Medicare Services (CMS) issued a proposed rule on April 16, 2019, to change the Medicare cost report form set for home health agencies. The new forms will be known as the CMS Form 1728-19. The Notice appeared in the April 16, 2019 Federal Register with a 60 day comment period. Comments are due by June 17, 2019. The proposed changes are intended to be effective for cost reporting periods beginning on or after January 1, 2019 and ending on or after December 31, 2019. This could be problematic if CMS sticks to this effective date as most agencies will be at least six months into the cost reporting period before the new forms become final and there is some new information that will be required.
Following is a summary of the proposed significant changes.
Worksheet S-3, Part I – Census Statistics
This worksheet has been modified to separately report the number of visits and patients for Medicaid services. Previously Medicaid was included with “Other” patients. Therefore, the counts will be Medicare, Medicaid and Other – visits and patients. It should be noted that Medicare visits here are reported based on date of service in the cost report period, not episode end date. Utilization data for completed episodes continues to be reported on Worksheet S-3, Part IV and generally comes from the PS&R report.
In addition to breaking out Medicaid, the number of visits and patients are now segregated for the following disciplines. Skilled Nursing Care statistics will be separately reported for RN’s and LPN’s, Physical Therapy and Physical Therapy Assistants, and Occupational Therapy and Occupational Therapy Assistants.
Worksheet S-3, Part V – Occupational Wage Data
This worksheet is an attempt to get specific wage and benefit data for each of the direct care cost centers. Wages and benefits will be separately reported for RN’s, LPN’s, Nursing Assistants / Aides. In addition, Physical Therapists, Physical Therapy Assistants, Physical Therapy Aides, Occupational Therapists, Occupational Therapy Assistants, Occupational Therapy Aides, Speech-Language Pathologists and Other Medical Staff. The same categories applies to any contract labor costs. It is very important to separate out direct cost for W-2 wages from contract labor on your financial statements.
With the detailed reporting of wages and contract labor, CMS is also requesting total paid hours for each of these categories. The purpose of this Worksheet is to compute an average hourly wage for each occupational category. One significant problem here is that some visits are paid on a per visit basis and may not have actual paid hours to report.
Worksheet A – Trial Balance of Expenses
This is the worksheet where total expenses from the agency are reported from the Trial Balance of the Financial Statements of the Agency. There are new cost centers created, mainly to match up to the new level of detail for visit reporting.
Line 5 – Remote Patient Monitoring – enter allowable administrative costs related to remote patient monitoring as described in 42 CFR 409.46 (a) through (d). This overhead cost is allocated on Worksheet B stepdown based on time spent by cost center.
Lines 16 and 17 – Skilled Nursing Care – separate cost for RN and LPN.
Lines 18 and 19 – Physical Therapy – separate cost for Therapists and Assistants
Lines 20 and 21 – Occupational Therapy – separate cost for Therapists and Assistants
Line 27 – Cost of administering vaccines – pneumococcal, influenza, hepatitis B and osteoporosis drugs. The cost of the actual vaccines is reported on line 26 – Drugs.
Line 29 – Disposable Devices – cost of disposable devices i.e., negative pressure wound therapy (NPWT) devices.
Line 30 – Telehealth – direct costs associated with telehealth. Remote Patient Monitoring is not a telehealth service.
The Federal Register Notice was published on April 16, 2019. Following is a link to the actual notice.
There is a 60-day comment period for these changes; instructions for submitting comments are available here:
https://www.govinfo.gov/content/pkg/FR-2019-04-16/pdf/2019-07500.pdf.
In addition, CMS has provided a link to the actual draft forms, instructions and a crosswalk comparing the Form 1728-94 to the Form 1728-19.
https://www.cms.gov/Regulations-and-Guidance/Legislation/PaperworkReductionActof1995/PRA-Listing-Items/CMS-1728-19.html?DLPage=1&DLEntries=10&DLSort=1&DLSortDir=descending
We encourage all of you to review these changes and provide comments to CMS. This must be done before June 17, 2019.
Please let us know if you have any questions.
