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S-10 Update: CMS Issues Revised Reporting Instructions

DATE: 10/06/2017

CMS issued new and revised instructions for charity care and bad debt data reported by hospitals on worksheet S-10 of the Medicare Cost Report. Proper reporting of these data is critical, as it is now used for the distribution of Medicare Disproportionate Share Hospital (DSH) funding.

To help with interpretation of the changes, CMS has made available several examples in a Medicare Learning Network (MLN) document.

The instruction changes are applicable to hospitals that have or are considering amending their fiscal year 2014 and/or 2015 Medicare cost reports. Changes are currently due to CMS by October 31—an extension from the original due date of September 30.

Below are the basic changes to the S-10 reporting instructions issued by CMS:

  • clarification of the definition of charity care to include uninsured discounts reported on line 20;
  • clarification of the instructions for line 21, column 2, for insured patients and non-covered charges for insured patients for days exceeding a length-of-stay limit;
  • clarification that Medicare and non-Medicare hospital bad debt reported on line 26 must be net of recoveries;
  • the addition of line 27.01, Medicare allowable bad debts for the hospital;
  • modified instructions for line 28 to only capture non-Medicare bad debt;
  • modifications to the calculation of costs for both insured charity care charges not subject to the cost-to-charge ratios (CCR), and insured non-covered days beyond a length-of-stay limit subject to CCR; and
  • modifications to the calculation of non-Medicare bad debt subject to CCR and non-reimbursed Medicare bad debt (deductible and coinsurance) not subject to CCR.

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