CMS Issues Clarifications, Corrections to Freestanding Hospice Cost Report Forms and Instructions
August 6, 2015 05:04 PM
Effective for cost reporting years starting on or after October 1, 2014, freestanding hospices are required to file the revised hospice cost report Form CMS-1984-14. The new freestanding hospice cost report significantly expands data collection requirements to supply greater detail related to hospice costs by level of care; data from the modified report may be used in future payment reform analyses by the Centers for Medicare & Medicaid Services (CMS). Form CMS-1984-14 underwent a lengthy review and comment process and was made publicly available in late August 2014. CMS has continued to receive recommendations to modify CMS-1984-14 to promote greater clarity and accuracy of the documents.
CMS recently issued Transmittal 2: New Cost Reporting Forms and Instructions -- Effective Date: Hospice Cost Report changes effective for cost reporting periods beginning on or after October 1, 2014 (dated July 31, 2015) to its website; the transmittal makes clarifying and correcting revisions to the freestanding hospice cost reporting forms and instructions as follow:
Worksheet A: Shaded column 1 of line 70.
Worksheet A-6: Modified form and instructions to separate reclassifications between salaries and other costs.
Worksheets B and B-1: Removed shading from column 7 of line 17 for both Worksheet B and B-1. Modified column labels on Worksheet B-1.
ELECTRONIC SPECIFICATIONS EFFECTIVE DATE:The electronic reporting specifications are effective for cost reporting periods beginning on or after October 1, 2014. For automated cost report software purposes transmittals 1 and 2 will be merged and implemented simultaneously.
Ted Cuppett of The Health Group provided the National Association for Home Care & Hospice (NAHC) with an explanation and analysis of the changes to Form CMS-1984-14 represented in Transmittal 2; his comments are as follow:
Transmittal 2 provide two (2) technical corrections to the Hospice Cost & Data Report as previously issued and makes one distinctive reporting change as follows:
CMS has eliminated the potential of assigning any salary costs to the “Nursing Facility Room & Board” cost center (Line 70 of Worksheet A). This is an appropriate technical correction as payments to nursing facilities in the form of room and board payments do not include any salaries and wages paid to hospice personnel.
CMS is allowing input (housekeeping statistics and cost) on line 17 of Worksheet B and B-1. This allows for housekeeping costs to be allocated to “Patient Residential Care Services” (Line 17), which is then allocated to all inpatient and residential units on the basis of in-facility days. The original cost report did not appropriately allow for the allocation of housekeeping costs.
Worksheet A-6 has been modified to require the reclassification of costs as salaries and wages or other costs. [T]his correction [is beneficial] inasmuch as it [supports] tracking the ultimate reporting of salary and wage costs. Salary and wage costs are used later in the cost report for purposes of allocating employee benefit and employee benefit department costs.
The changes identified above were included in changes to the “electronic reporting specifications.” Other technical corrections were also made to enhance electronic cost reporting edits.
Special thanks to Ted Cuppett and The Health Group for this analysis.