Preserving Your Fair Share of DSH Reimbursement

| 7/25/2017

Uncompensated Care Reporting: Medicare Disproportionate Share Hospital Payments

On April 28, 2017, the Centers for Medicare & Medicaid Services (CMS) issued the federal fiscal year (FFY) 2018 inpatient prospective payment system/long-term care hospital prospective payment system proposed rule. CMS has proposed that the uncompensated care pool (UCP) calculation for Medicare disproportionate share hospitals (DSH) will transition from the current use of the days proxy to using non-Medicare uncompensated care reported on the Medicare cost report (worksheet S-10, line 30). The transition will be phased in over a three-year period as follows:

  • FFY18
    • Year 1 Factor - 2012 Days Proxy
    • Year 2 Factor - 2013 Days Proxy
    • Year 3 Factor - 2014 S-10

  • FFY19
    • Year 1 Factor - 2013 Days Proxy
    • Year 2 Factor - 2014 S-10
    • Year 3 Factor - 2015 S-10

  • FFY20
    • Year 1 Factor - 2014 S-10
    • Year 2 Factor - 2015 S-10
    • Year 3 Factor - 2016 S-10

What does this mean for you? The UCP calculation is used to distribute 75 percent of the DSH payment pool to eligible hospitals. With this transition to using the non-Medicare uncompensated care amount from worksheet S-10 of the Medicare cost report, hospitals must verify that the amounts reported on worksheet S-10 are accurate and auditable. CMS has issued a notice that hospitals wishing to amend their FFY14 cost reports to revise worksheet S-10 data must do so by Sept. 30, 2017, in order to be included in the December 2017 update of the Healthcare Cost Report Information System (HCRIS). CMS is developing an audit program to be used by the Medicare Administrative Contractors (MACs) when auditing the data reported on worksheet S-10 beginning with FFY17 cost reports.

How can Crowe help? We have developed an automated process that uses the Crowe Revenue Cycle Analytics benchmarking solution to extract the charity care and non-Medicare bad debt amounts to be reported on worksheet S-10 and provide you with an account-level report to help support the amounts reported. This process can save you considerable time during the reporting process and is designed to provide you with an accurate listing of accounts.

Please contact Ron Wolf to discuss options available for preserving your fair share of DSH reimbursement.


The Crowe Revenue Cycle Analytics (Crowe RCA) solution was invented by Derek Bang of Crowe. The Crowe RCA solution is covered by U.S. Patent number 8,301,519.

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