On December 29, 2022, CMS issued Transmittal 18, which includes several revisions to the Hospital and Health Care Complex Cost Report (2552-10). In this Transmittal, CMS addresses the following items related to Medicare disproportionate share (DSH), bad debts, and uncompensated care:
- Creation of Worksheet 3A – New format for Medicaid–eligible days (DSH-eligible hospitals).
- Creation of Worksheet 2A – Several new fields are added to the reporting requirements for Medicare bad debts.
- Creation of Worksheets 3B and 3C – Provides a standard format for the information required to support charity care and bad debt amounts claimed on Worksheet S-10.
- Creation of an additional S-10 Worksheet (Part I and Part II) – Part I is intended to capture the entire hospital complex uncompensated care while Part II is designed to capture hospital-only data.
The changes are effective for cost report periods beginning on or after October 1, 2022. FORVIS expects these modifications to significantly impact hospital reimbursement for those who are unprepared. Specifically, the new reporting requirements relating to Medicare bad debts and Worksheet S-10 could pose challenges for many hospitals. The expanded data requirements will create additional work for providers and likely generate more audit scrutiny. We recommend working with your IT group to develop a plan to capture these new data elements.
FORVIS has been preparing for these changes since 2020. If you have questions or need assistance, please reach out to a professional at FORVIS or submit the Contact Us form below.