As you may know, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule on April 16, 2019 for a new cost report form set for home health agencies, Form CMS 1728-19. With the comment period having ended June 17, 2019, we provided comments to CMS which can be viewed in the file at the bottom of this article. While the core of the cost report form remains intact, there are significant changes in the form set. The update requires home health agencies to change their recordkeeping and data requirements to comply with the new forms.
The following is a summary of the key changes and updates.
EFFECTIVE DATE OF THE NEW COST REPORT FORMS
The draft instructions state, in Section 4700, the effective date is for cost reporting periods beginning on or after January 1, 2019, and ending on or after December 31, 2019. It is our belief that CMS used this as a place holder, and the actual effective dates may be subject to change. If accurate, these dates would prove to be problematic. We recommended that CMS modify this effective date.
VISITS AND PATIENT CENSUS BY PAYOR BY DISCIPLINE (WORKSHEET S-3, PART I)
Currently, patient census statistics (number of visits and number of patients by service discipline) are separately reported as “Medicare” and “Other”. The new worksheet now breaks out “Medicaid” statistics from “Other” statistics. As of now, Medicare Advantage is reported as “Other”. We assume this will be the same. CMS has not clearly stated how to report Medicare Advantage and Medicaid Managed Care census statistics. Statistics will now be separately reported under Skilled Nursing Care as RN or LPN. For Physical Therapy and Occupational Therapy, the statistics will need to be separate for Therapists and Therapy Assistants.
OCCUPATIONAL WAGE DATA (WORKSHEET S-3, PART V)
The revised cost report includes a new Worksheet (Worksheet S-3, Part V) which captures salaries and fringe benefits by individual occupational category. There is a separate section for contract labor categories, thus W-2 wages and contract labor are separately reported. Total “paid hours” are reported for each category, and the average hourly wage is computed. Capturing total paid hours can be an issue in light of the home health compensation methods and the capturing of hours for full time staff.
NEW TRIAL BALANCE COST CENTERS (WORKSHEET A)
With the changes in the new detail for census statistics for nursing and therapy (above), the direct cost will also need to be separately identified for Skilled Nursing (RN and LPN), Physical Therapy, and Occupational Therapy (Therapists and Therapy Assistants). This includes salaries, mileage, contract labor and employee benefits / payroll taxes if direct costed.
A new cost center was added for Remote Patient Monitoring, which is now an allowable administrative cost. CMS clearly stated that Telehealth is NOT Remote Patient Monitoring. Telehealth has a separate cost center.
HHA BASED HOSPICE
Home Health Based Hospices complete the Worksheet “O” series of the form. The direct cost flows from Worksheet A, line 57, to Worksheet B for allocation of home health overhead, then to the “O” series. Of course, the direct cost for Hospice is also reported by level of care in the “O” series. There are numerous inconsistencies between Worksheet A and Worksheet O. In addition, the Worksheet “O” series did not incorporate the changes made to the Freestanding Hospice cost report, Form CMS 1984-14 for reporting of costs.
Contact your VonLehman Healthcare Reimbursement team to understand what these revisions mean for you and to ensure your reports are in compliance with the new regulations.