Stay ahead of the curve and prepare your S-10 data in a MAC-approved format.
Welcome to the second episode of our Worksheet S-10 series. As we get through the 2018 S-10 audits and start getting ready for the 2019 audits, we want to focus on the data request format used by auditors to review the charity and bad debt worksheet S-10 data. The format has evolved slightly from the 2017 audits to the 2018 audits and may continue to be tweaked as lessons learned and feedback filter back to CMS and MACs for 2019, 2020 and beyond.
The Attachment D template lays out a standard format for the detail behind: Charity Care, Total Hospital Bad Debt, and Patient Payments. In addition to log specific fields, the listing templates include the following attributes:
Insurance Status (Insured vs. Uninsured)
Primary Payor Plan
Secondary Payor Plan
Patient Identification Number (PCN)
Patient Date of birth
Social Security Number
Service Indicator (Inpatient or Outpatient)
As things stand today, adhering to the following guidance is key to producing a clean Worksheet S-10.
Charity Care should
· Include the total amount that reconciles to the Line 20 Charity Care Charges reported on Worksheet S-10
· Include any non-covered Medicaid charges covered under the Hospital’s financial assistance policy
· Only encompass the coinsurance, copay, and deductible amounts written off to financial assistance for insured accounts
· All be written off within the cost reporting period, regardless of date of service
· Include both positive and negative adjustments (adjustments and reversals of charity adjustments)
· Not include amounts reported as reimbursable Medicare bad debts
· Not include professional charges. If the hospital bills for professional services and they are not partitioned on a different system, the template will request the charges broken out by revenue code to ensure that no professional charges are claimed on worksheet S-10.
Total Hospital Bad Debt
This listing should reconcile to the amount reported on Line 26 of Worksheet S-10 and should encompass all payor bad debts, including the amounts reported as reimbursable Medicare bad debts. Some MACs will request a reconciliation of the total amount reported to the hospital’s financial statements with an explanation on any material variance. One important thing to note is that the timing of the Medicare vs. Non-Medicare bad debt reporting may vary depending on the hospital’s policies and procedures. Medicare reimbursable bad debts are required to be returned from any and all external collection agencies before qualifying for reimbursement, but prior to the return and ceased collection efforts an allowance for bad debts would likely have been made prior to or when the amount was placed with collections. This variance in reporting method between payors may naturally create a variance in comparison to the hospital’s financial statements.
The total amount on this tab should reconcile to Line 22, Patient Payments for amounts previously written off to Charity Care reported on Worksheet S-10. For cost reports with a fiscal year beginning after 10/1/2016 when the charity reporting method switched from the date of service to the date written off to Charity Care, the total amount reported on this line is almost expected to be $0. In the event of a patient payment for amounts previously written off to Charity Care, which is not an expected occurrence, often times the previous charity adjustment would be reversed in the amount of the payment in order to balance the account back to $0. Therefore, it is not necessary to report the payments nor the adjustment reversals as this would be a duplicative offset to the total reported charity amount.
Stay tuned for future editions to our worksheet S-10 series.
Next, we will look at some data trends over the last number of years and take a peek into how hospitals across the nation have reacted to the importance now placed on Worksheet S-10
Have questions or need assistance assembling your hospital’s Worksheet S-10 data? For further information please contact Adam Reese at firstname.lastname@example.org or 509-994-0778.