Every three years, CMS conducts an occupational mix survey (OMS) and requires that all Prospective Payment System (PPS) hospitals complete and submit the survey to their respective Medicare Administrative Contractor (MAC). The next OMS will likely be due to the MAC in early July 2023 and will be based on the 2022 calendar-year data. The 2022 OMS is expected to be used in setting the occupational mix adjustment factor (OMAF) for federal fiscal years 2025, 2026, and 2027. It is important for hospitals to not overlook the impact of having an accurate OMAF. Being off just slightly in the reporting can have a material impact on the hospital’s wage index and ultimately the Medicare reimbursement.
Conceptually, the OMS requires a hospital to identify and separate out various nursing category positions for both salaried and contracted positions for selected Medicare cost report cost centers. The nursing utilization by RNs, LPNs, aides, and medical assistants is compared to similar data for all PPS hospitals in the country to arrive at the OMAF. The nursing versus other data is used in arriving at the percentage of the wage index that will be adjusted by the OMAF. While it may appear simple on the surface, accurate completion of the OMS requires a thorough understanding of the wage index instructions and calculations.
Challenges related to the OMS include not only knowing the wage index rules, but also recalling the details from three years ago when the last survey was completed. For most hospitals, significant change has occurred since 2019 when the last survey was filed, such as the creation of new positions, payroll systems, IT systems, and contracts. In addition, the OMS can be challenging due to the following factors:
- Confusing or vague instructions for completing the OMS
- Existing demands on reimbursement staff
- Complexity of the actual occupational mix adjustment calculation, its data components, and the methodology used to incorporate the adjustment into the wage index
- Lengthy verification/validation process
- Turnover within the MAC
For these reasons, we recommend getting an early start on the OMS. While the forms are not available, it is not too early to develop a plan for gathering and compiling the OMS.
Once the updated survey and instructions are available, you can find them on the CMS website. For more information or questions about the OMS, please reach out to a professional at FORVIS or submit the Contact Us form below.