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Worksheet S-10 Series Episode 1 - Charity and Discount Policies

Fine tuning your Hospital financial assistance policies can maximize your uncompensated care payments and protect against audit adjustments.

This is the first edition in our Worksheet S-10 series. We will attempt to untangle the web that has been woven by CMS. Worksheet S-10 has been solidified as the main source driving Uncompensated Care reimbursement to hospitals. The guidance offered has changed dramatically over the past number of years and continues to evolve with every new proposed and final IPPS ruling as well as with intermediate publications from CMS. In this series we’ll take specific topics from the broader umbrella of S-10 and explain our interpretation of them as well as lessons from our experience in working with auditors in an effort to help your organization maximize and accurately report on reimbursement as it relates to uncompensated care. Our first topic is charity and discount policies.

Similar to Medicare bad debt, Medicare Administrative Contractors (MACs) auditors are seeking to review policies and procedures in a BIG way. Uninsured discounts are in play to be included on Line 20 (Charity care charges and uninsured discounts). However, if you do not have a policy specifying how these discounts are allocated and calculated, much of your reimbursement could be at risk. CMS has made it clear that courtesy discounts should not be reported on this line. Courtesy discounts can be defined as any discount given to a patient that is not part of the hospital’s written financial assistance policy, such as prompt pay discounts, employee discounts, friends, and family discounts, etc.

Another avenue of reportable charity and discount amounts that may not be on the top of everyone’s mind are non-covered Medicaid charge amounts. These amounts will vary from state-to-state, but can accumulate to a material shift in a hospital’s reimbursement if reported accurately. These non-covered charges must be specified in the Hospital’s financial assistance policies and be written off as such in order to be supportable in the event of an audit.

One final note, whether the discount is granted based on a patient’s financial situation or non-covered services, timing is everything. Going forward, ensure that when you are assembling your worksheet S-10 you account for charity and discounts based on the time the discount was adjusted off the balance and not based on the date of admission or discharge.

Stay tuned for future editions to our worksheet S-10 series. Next, we will tackle “Attachment D” the standard data request format for worksheet S-10 data.

Have questions or need assistance assembling your hospital’s worksheet S-10 data? For further information please contact Adam Reese at or 509-994-0778.


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