HFMA Comments on Acute Hospital Medicare Cost Report Issues Created by COVID-19

HFMA submitted a comment letter to CMS expressing its concern that the pandemic and associated relief efforts have created a number of technical Medicare cost report issues that need to be addressed. Otherwise hospitals may owe (or be due) a significant payable due to circumstances beyond their control and have future rates set too high (or low). Both situations will further jeopardize the financial sustainability of many hospitals that have seen their income statements and balance sheets weakened by the pandemic at a time when they are most needed by the communities they serve. Specifically, these issues include:

  • Intern and resident counts for Indirect Medical Education  (IME) /Direct Graduate Medical Education (DGME) payment calculation
  • Medicare ratio for DGME payment calculation
  • Uncompensated care claimed on worksheet S-10
  • Medicaid and Supplemental Security Income (SSI) volumes for DSH-eligible hospitals
  • Ratio of costs to charges
  • Worksheet A-8 treatment of COVID-19 expenses 
  • Worksheet A-8 treatment of Payment Protection Program (PPP) loan forgiveness
  • Medicare Accelerated Payment Program cost report treatment – Worksheet A-8
  • Rural health clinic (RHC) productivity standards
  • Medicare transplant volumes and survival rates – conditions of participation
  • Worksheet G-3: Reporting Revenues Associated with CARES Act Grants and Loan Forgiveness

Download the comment letter