2016 Audit Update - PowerPoint Presentation

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2016 Audit UpdateNew Features & ProceduresSeptember 2016Prepared by: Zack PaluckaPresented by: Dave Cipollone

Proprietary and ConfidentialSlide2

Hi-Tech AuditsFindings and ObservationsSlide3

Charity Care ChargesFee based Medicare bad debts are not allowable as Charity Care Charges on W/S S-10, line 20 .Medicare Part C bad debts are not allowable as Charity Care Charges on W/S S-10 line 20.Medicare bad debts are reported on S-10, Line 27. Non-Medicare and non-reimbursable Medicare bad debts are reported on S-10, line 28.Slide4

Charity Care Charges (Cont.)Providers don’t have the option to claim the deductible or coinsurance from a Medicare account because a decision was made not to attempt to collect the amount as a bad debt. Medicare deductibles and coinsurance can’t be claimed as Charity Care Charges.Charity Care Charges reported on W/S S-10 line 20 must be for services rendered for the current cost report.For example: For a 6/30/2015 FYE cost report the services must have been rendered between 7-1-14 and 6-30-15.Charges for accounts from previous years that were not collected can’t be reported on W/S S-10 in a subsequent year.Slide5

Charity Care Charges (Cont.)For example: Charges that were unable to be collected for services rendered on October 1st 2012, can’t be reported on the 6-30-15 FYE cost report as a charity care charge, even though this was the period when collection efforts were exhausted.Providers can request a reopening to report Charity Care Charges in the proper cost reporting year.Slide6

Medicare Part C Days (Cont.)CMS has required providers to bill for these days since 2003. We can’t accept documentation in lieu of billing.We use the number of Part C days from PSR 118 to determine Hi-Tech payments.It is crucial for CAHs to bill for these days. Not billing will have a large negative effect on Hi-Tech reimbursement.Send all Part C inquiries to Camille.Wolff@novitas-solutions.comSlide7

QUESTIONS?Slide8

EHR Non-Allowable AssetsFindings and ObservationsSlide9

Proprietary and ConfidentialEHR Non-Allowable AssetsThe following listed assets are considered non-allowable for EHR purposes.A new HVAC system or upgrade that may be required in order to maintain the environment for the new servers, or other technology.

Electrical infrastructure upgrades needed to support the new computer system.

New additions that need to be built to house a new server, etc.

Backup power systems "necessary" to run a server

Drug dispensing systems that are used (that are linked to the EHR system for recording purposes.)

X-ray equipment (the images from which are stored in the EHR system)Slide10

EHR Non-Allowable Assets (Cont.)New data center related to the use of the EHR systems or data.Computer desks, cabinets, carts, etc. that are generally separately capitalized as individual assets, and can't themselves be considered as computer hardware or software are not allowed for the EHR incentive. They can still be depreciated under normal Medicare asset rules, but not as part of the incentive.Slide11

Other examples of Non-AllowableEnd User Training (for staff that will ultimately be using the system) - This is not normally capitalized under GAAP or Medicare because the value does not attach to the asset itself, it attaches to the employee.Data Conversion - Labor or other costs related to the process of converting data from the old system to the new system are not allowed, because they are not normally capitalized under GAAP or Medicare. However, the costs of computer hardware or software that are purchased for the purpose of converting the data may be capitalized. Interest - This cost is specifically disallowed under the legislation.Slide12

Other examples of Non-Allowable (Cont.)Maintenance Agreements - These services do not meet the criteria to be capitalized under GAAP. The same rule will apply to the Medicare EHR incentive program. Any portion of the purchase price of these assets related to these maintenance agreements must be carved out and separately expensed as a normal operating cost (i.e. a prepaid expense).Slide13

Other examples of Non-Allowable (Cont.)Remote Hosting Services - Remote hosting services are considered to be an operating lease of space and other services. Similar to the maintenance agreements discussed above, these would not be capitalized under GAAP, thus will not be allowed as part of the EHR incentive program. Any portion of the purchase price of these assets related to remote hosting services must be carved out and separately expensed as a normal operating cost (i.e. a prepaid expense).Slide14

QUESTIONS?Slide15

CMS InitiativesSlide16

Sub-Intensive Care BedsThe instructions at PRM 15-1, Chapter 22 Section 2207.II B state: “Some hospitals have units which provide a level of care between other general routine and intensive care. These units are typically designated as sub-intensive, sub-acute, progressive, intermediate care units, etc. Sub-intensive care type units are considered part of the total spectrum of general routine care and are therefore reimbursed by combining the reasonable costs of the care furnished in the unit with the reasonable costs of care in other general routine areas.”Slide17

Cost reporting impactThis distinction will have a reimbursement impact on IME reimbursement.The beds and bed days available must not be included in the Nursery cost center. The beds and bed days available for these types of units must be reported on W/S S-3, Part I, line 1, columns 2 and 3. (Hospital Adults and Peds)The bed days available from these units will then be included in the denominator of the IME calculation. All corresponding costs and statistics must also be reported in the Adults and Peds cost center.Slide18

Legal Operator of Allied Health Schools(f) Criteria for identifying programs operated by a provider. (1) Except as provided in paragraph (f)(2) of this section, for cost reporting periods beginning on or after October 1, 1983, in order to be considered the operator of an approved nursing or allied health education program, a provider must meet all of the following requirements: (i) Directly incur the training costs. Slide19

Legal Operator of Allied Health Schools (Cont.)(ii) Have direct control of the program curriculum. (A provider may enter into an agreement with an educational institution to furnish basic academic courses required for completion of the program, but the provider must provide all of the courses relating to the theory and practice of the nursing or allied health profession involved that are required for the degree, diploma, or certificate awarded at the completion of the program.) Slide20

Legal Operator of Allied Health Schools (Cont.)(iii) Control the administration of the program, including collection of tuition (where applicable), control the maintenance of payroll records of teaching staff or students, or both (where applicable), and be responsible for day-to-day program operation. (A provider may contract with another entity to perform some administrative functions, but the provider must maintain control over all aspects of the contracted functions.) (iv) Employ the teaching staff. Slide21

Legal Operator of Allied Health Schools (Cont.)(v) Provide and control both classroom instruction and clinical training (where classroom instruction is a requirement for program completion), subject to the parenthetical sentence in paragraph (f)(1)(ii) of this section. (2) Absent evidence to the contrary, the provider that issues the degree, diploma, or other certificate upon successful completion of an approved education program is assumed to meet all of the criteria set forth in paragraph (f)(1) of this section and to be the operator of the program.Note: We will be requesting a copy of the diploma for each school as part of our desk review or audit.Slide22

QUESTIONS?Slide23

2016 Audit UpdateNovitasphere and Secure E-mailsSeptember 2016Prepared by: Spenser ErcolePresented by: Dave Cipollone

Proprietary and ConfidentialSlide24

AgendaNovitasphere OverviewFAXINATION SecureZIP TroubleshootingSlide25

NovitasphereWhat is it?Free web-based PortalPart A users will have access to obtain patient Eligibility, submit Medical Review Records and Provider Audit & Reimbursement Cost Reports For demonstrations and more information on Novitasphere visit:JH Providershttp://www.novitas-solutions.com/webcenter/portal/Novitasphere_JH/ JL Providershttp://www.novitas-solutions.com/webcenter/portal/Novitasphere_JL/ Slide26

What can you Submit?In addition to a cost report, you can submit: Cost Report Reopening: Used for Submission of reopening Requests for a cost report after it has been settled Cost Report Appeals: Used for the submission of supporting documents for cost reposts that are under appeal SSI Realignment Request (DSH):Used to request an update to a provider’s disproportionate share statistics Provider-Based Determination: Used to request initial setup or change in a unit’s provider-based status Wage Index/Occupational Mix Submissions: Used to upload documentation for the yearly wage index and occupational mix audits Desk Review/Audit Additional Documentation: Used to upload documentation requested by the Novitas audit staff during the time of a desk review and/or audit

Submit FOIA Request:

Used to submit a Freedom of Information Act request for Medicare cost reports

Submit PS&R Request:

Used to submit a Provider Statistical & Reimbursement report request for fiscal years not covered on the CMS PS&R online system. Providers may utilize this selection if they are currently experiencing PS&R access issues as well

General Correspondence:

Used to submit documentation for items not covered in the above-mentioned table selections; such items include:

Request for Interim Rate Change

Request for Tentative Settlement Change

TEFRA Exception Request

SCH Low Volume Request

Request for Change in Statistical Basis

CMS Tie-In-Notice

Bankruptcy

Other Supporting Documentation

50%Reduction Request Slide27

Live Chat FeatureSlide28

MailBox Secure Message Communications Slide29

Helpful LinksNovitasphere Part A User Manual:http://www.novitas-solutions.com/webcenter/content/conn/UCM_Repository/uuid/dDocName:00126973 Part A Novitasphere Frequently Asked Questions:http://www.novitas-solutions.com/webcenter/content/conn/UCM_Repository/uuid/dDocName:00126974 Eligibility Guide:http://www.novitas-solutions.com/webcenter/content/conn/UCM_Repository/uuid/dDocName:00098576Cost Report Submission Quick Steps:http://www.novitas-solutions.com/webcenter/content/conn/UCM_Repository/uuid/dDocName:00134848 Novitasphere Portal Dedicated Phone Number:1-855-880-84248:00am to 5:00pm – ET7:00am to 4:00pm – CTSlide30

FAXINATIONWhat is it?Does not affect the way Provider sends/receives faxes.Internal change that allows Novitas to send/receive faxes electronically. Fax numbers have not changed.Part A Med Review 412-802-1833Provider Audit 412-802-1757Part A Accounts Receivable 412-802-1836 SecureZIP email attachments still preferred method for sending protected health information (PHI) and personally identifiable information (PII).Slide31

Having Trouble with SecureZIP?Reference SecureZIP troubleshooting page on Novitas website by following these steps:Link to Novitas Solutions WebsiteSlide32

Accessing SecureZIP TroubleshootingSelect Jurisdiction LSlide33

Accessing SecureZIP TroubleshootingSelect “Cost Reporting”  “More”Slide34

Accessing SecureZIP TroubleshootingSelect appropriate linkSlide35

Accessing SecureZIP TroubleshootingAccept AgreementSlide36

Accessing SecureZIP TroubleshootingThere it is! Slide37

QUESTIONS?