Medicare Posts

Significant Changes to the Wage Index Development Timetable for FFY 2016

Tuesday, May 27th, 2014

Earlier this month in its Federal Fiscal Year 2015 Proposed Rule, CMS released the proposed FFY 2016 Wage Index Development Timetable and there are significant changes. The FFY 2016 wage index process will commence as early as late May 2014 with the publication of the preliminary FFY 2016 Wage Index Public Use File (PUF). This file was previously posted in the September/October timeframe. As a result, all subsequent dates for FFY 2016 have been drastically moved up as well.

CMS will separately release the preliminary Calendar Year (CY) 2013 Occupational Mix Survey PUF in early to mid-July as these surveys will not be submitted by providers until the July 1, 2014 deadline.

Accordingly, the deadline for hospitals to submit any revisions to its CY 2013 Occupational Mix Survey and FFY 2016 wage index (Worksheet S-3, Parts II, III & IV) data are required no later than early October 2014 (the actual date has yet to be determined by CMS). Providers wishing to make changes to the data that appears in the preliminary FFY 2016 Wage Index and Occupational Mix Survey PUFs must have all supporting documentation submitted to its Medicare Administrative Contractor (MAC) by this to be determined date. As a result of the earlier date of submission, MACs will be required to complete their wage index desk reviews by mid-December 2014. This date is moved up from the late January timeframe historically. All other PUF release dates coincide with previous years.

HFS can help with all your occupational mix and wage index needs.  If you have any questions or would like assistance filing wage index revisions, please contact Ryan Sader at, or 714-656-4485. Our secure wage index client portal provides updates on changing regulations and presents detailed instructions and tips for reporting accurate wage index information on the Medicare cost report.

Medicare Pay for Performance

Monday, May 19th, 2014

guy_workingEach year the publication of the IPPS Proposed Rule gives us more information about the Medicare Value-Based Purchasing Program, Medicare Readmissions Reduction Program, and the new Hospital-Acquired Conditions Program. These are collectively known as the Medicare Pay for Performance Programs. Boiled down to their essence, these programs put your hospital’s Medicare reimbursement at risk based on complex quality measures that become more complex each year. (more…)

Medicare Occupational Mix Survey 101 – What you need to know

Monday, April 7th, 2014

Once every three years, CMS asks hospitals to complete the Occupational Mix Survey. The survey is due on July 1, 2014, a little over two months from now. Are you ready?

CMS uses the Occupational Mix Survey (OMS) to gauge the types of nursing personnel hospitals hire. CMS uses this information to benchmark the proportion of high cost employees, such as registered nurses, against hospitals across the country. If, for example, a hospital hires a higher proportion of registered nurses than the average hospital in the U.S., its Average Hourly Wage is adjusted downward so that its hiring decisions (i.e., more high cost employees) does not artificially inflate its Average Hourly Wage.

The Survey Takes Some Time to Prepare
At face value, the OMS seems simple enough to prepare. It requires input for only five types of labor – registered nurses, licensed practical nurses and surgical technicians, nursing aides, medical assistants, and the catch-all, “all other.” Despite this simplicity, CMS estimates that a hospital should expect to spend 480 hours to accurately prepare the survey. So what takes so long? (more…)

Information for Clinics and other Safety Net Providers

Tuesday, February 18th, 2014

There are several updates on regulatory and other changes that impact RHCs, FQHCs and other clinic based providers. The following is information on: Medi-Cal Code 18 rate setting, tracking your combined payments, when you should bill the secondary bill, and Medicare rate setting.

calculator-handsMedi-Cal Code 18 Rate Setting Results
DHCS implemented Medi-Cal managed care into the remaining California counties effective November 1st. Clinics have either Anthem Blue Cross (“ABC”), Centene (“CHW”) or Partnership (“PHP”) as their managed care plan. Clinics should have submitted their initial Form 3100 to DHCS to obtain an initial rate Code 18 (“wraparound”) rate. We’ve noticed that DHCS Audits group has been approving the initial rate at 100% of the requested amount. This leads us to advise the following: (more…)

Healthcare Organizations Can Expect Financial Pinch in 2014

Wednesday, January 15th, 2014

The Patient Protection and Affordable Care Act (PPACA) is a game changer for hospital and health system revenues, costs, and operations. In addition, legislative and regulatory actions, as well as industry trends, will produce a challenging economic landscape for providers in 2014. HFS executives provide insight on the significant changes and trends that healthcare organization executives can expect in 2014.

CEO Insight on the Affordable Care Act
Trahan WhittenThe largest issue facing healthcare organizations is the multi-faceted impact of the PPACA on both revenues and expenses. Revenues are decreasing dramatically from both Medicare and Medicaid (Medi-Cal), which do not even cover the cost of care to their beneficiaries. At the same time, insurance companies are demanding lower rates and eliminating providers from their networks, which cannot compete on costs. This will place a premium on healthcare organizations’ ability to manage cost reduction, both labor and non-labor and to achieve revenue recovery in 2014. HFS is perfectly positioned to help accomplish these difficult competing priorities.
-Trahan Whitten


Medicare Bad Debts-FY 2013 and Beyond

Monday, August 26th, 2013

money_stethoscopeThe Middle Class Tax Relief and Job Creation Act of 2012 (the “Act”) delayed the implementation of significant reductions to Medicare physician payments that would have occurred in federal fiscal year (FFY) 2013.  In the budget neutral environment that now defines the Medicare and Medicaid programs, “funding” for this delay has to come from somewhere else within the system.  Thus, the Act also included several revisions to Medicare bad debt policy, some of them significant.  These changes will have varying impacts on Medicare bad debt reimbursement for hospitals, critical access hospitals, FQHCs and RHCs, and skilled nursing facilities.  In total, Medicare bad debt reimbursement for these types of providers is projected to decrease by almost $7 billion through FFY 2022.


Meeting the Health Insurance Exchanges Challenge

Monday, June 24th, 2013

Understanding the Financial and Operational Impact

The next stage in what is being called the largest change in American healthcare since the adoption of Medicare/Medicaid in 1965 begins on October 1, 2013, when Health Insurance Exchanges (or Marketplaces) are scheduled to open to enroll participants for coverage, which will begin on January 1, 2014.

thescopecalculatorAs the October 1 date rapidly approaches, some see this as an important step toward universal healthcare, while others see it as a potential “train wreck.” Will the Exchanges be able to meet deadlines for enrollment and coverage implementation? To date, 16 states and the District of Columbia have established state exchanges, including Washington, Oregon, California, Idaho, Nevada and Hawaii. The remaining states will be in federally facilitated marketplaces or a state/federal partnership exchange model. (more…)

Healthcare Reform Impacts FQHCs and RHCs in California

Tuesday, May 14th, 2013

PatientSignInAmong the changes mandated in the Affordable Care Act is the expansion in the next few years of Medi-Cal eligible patients. As part of the implementation of California’s Medi-Cal program, Medi-Cal managed care will be arriving in the 25 counties not currently using the plan. This now goes into effect on September 1, 2013. For those already enrolled in managed care plans, there are significant changes in the annual reporting.


HIPAA Compliance FAQs

Monday, April 8th, 2013

QandACommon Questions we’ve received from clients about HIPAA Compliance changes.

Q: If you have a deceased patient, does HIPAA still apply?

A: Yes, the medical record remains confidential regardless of the

patient’s status.

Q: What are the rules for emailing or texting protected health information (PHI) to outside vendors?

A: It must be under a Business Associates Agreeement and it must have an encrypted secure line. Standard text messaging is not HIPAA compliant.


Relief from DPNF Rate Cuts

Thursday, January 31st, 2013

Supplemental Payments for Public DPNFs Are Available

Last month, a federal appeals court cleared the way for the AB97 Medi-Cal rate cuts to take effect. This makes it nearly certain that severe DPNF rate cuts (the 08-09 rates less 10%) will be implemented retroactive to June 1, 2011. For many facilities, the resulting rates are 10-20% below what the normal rates would be. This means that DPNFs, many of whom are almost wholly reliant on Medi-Cal payments, will soon be assessed a large payback by the state. However, a long-standing but little known state program is available to provide CPE-generated supplemental payments for publicly-owned or operated DPNFs. While this program will not replace the entire shortfall, it will still provide significant relief of at least 50% of the rate cuts.

DPNF Public Hospital Supplemental Payment Program

The Medi-Cal DPNF supplemental payment program has been in existence since 2001. It is similar to the hospital outpatient program (AB915) in that public DPNFs can claim a supplemental payment equal to the federal share of the amount by which costs exceed the payments received. In past years, prior to the rate cuts, only DPNFs with rates above the statewide median (currently $416.95) qualified for this program, because they were the only ones whose rates fell below projected costs. However, with the rate cuts of recent years, DPNFs with rates below the median now qualify for the program.

Timely Claim Forms Submittal!

The state has only a two-year window in which to claim the federal portion of the CPE from CMS. This means that DPNFs must be timely about submitting the claim forms. The state uses quarterly claim forms, and most DPNFs that already participate in the program submit a claim every quarter. DPNFs newly affected by the rate cuts should submit claim forms for quarters as far back as allowed.

HFS Can Help

HFS is assisting district and county DPNFs in preparing the claims for supplemental payment. Our professionals can provide a range of assistance depending on your organization’s specific needs, from simply providing education, to reviewing facility-prepared claims submissions, all the way to preparing the actual claims and following through to final payment.

We would be happy to answer any questions or assist with your DPNF supplemental payments. Please contact John Pfeiffer at 510-867-1314 or