AHA comments on CMS proposal for using Worksheet S-10 data

The AHA yesterday urged the Centers for Medicare & Medicaid Services to take additional steps before using Worksheet S-10 data to determine a hospital’s uncompensated care, given the impact this calculation has on the distribution of Medicare disproportionate share hospital payments. “We urge CMS to take additional steps to ensure the accuracy, consistency and completeness of these data prior to their use,” wrote AHA Executive Vice President Tom Nickels. “This entails auditing the S-10 data, as well as making other modifications to the S-10 worksheet, including, but not limited to, adopting a broad definition of uncompensated care costs to include all unreimbursed and uncompensated care costs, such as Medicaid shortfalls and discounts for the uninsured. Additionally, we urge CMS to restore excessive documentation and coding payment cuts to the inpatient PPS base in FY 2018.” In its inpatient prospective payment system final rule for fiscal year 2017, CMS proposed incorporating Worksheet S-10 data into the computation of uncompensated care payments by 2021.