CMS Cost Reporting Delayed as Hospitals Question Proposed Changes

January 18, 2021 - CMS has delayed the filing deadline for cost reports by two months for most healthcare organizations because of the ongoing COVID-19 pandemic.

The agency posted in a COVID-19 Frequently Asked Questions (FAQs) document on its website earlier this month that it will delay the filing deadline of Fiscal Year End (FYE) Oct. 31, 2019 and FYE November 30, 2019 cost reports until June 30, 2020.

CMS will also delay the filing deadline of the FYE Dec. 31, 2019 cost reports until August 31, 2020. For the FYE Jan. 31, 2020 cost report, the extended due date is August 31, 2020. For the FYE Feb. 29, 2020 cost report, the extended due date is September 30, 2020.

For any cost reporting period not identified in the FAQ and ending on a date between Mar. 1 and Dec. 31, 2020, CMS is giving providers an additional 60 days from the initial due date to file cost reports.

The new filing deadlines apply to all provider types, including hospitals, skilled nursing facilities, home health agencies, hospices, and federally qualified health centers.

The update comes as hospitals comment on changes to cost reporting requirements proposed by CMS in November 2020.

The agency released a notice of proposed information collection in which it announced intentions to make changes to Form CMS- 2552-10, otherwise known as the Hospital and Health Care Complex Cost Report.

Providers must submit the cost report to CMS each year in order to participate in Medicare. CMS then uses data from the reports to set reimbursement rates and carry out other responsibilities, such as projecting the Medicare Trust Fund.

The proposed changes to the cost report include adding a new worksheet called S-12 that will document median Medicare Advantage organization negotiated charges by Medicare severity diagnosis related group (MS-DRG), as mandated by the final rule for the 2021 Inpatient Prospective Payment System (IPPS), and several modifications to hospital uncompensated and indigent care data reporting on worksheet S-10.

CMS also proposed to add a line on worksheet G-3, statement of revenues and expenses, so hospitals can report aggregate revenue received for COVID-19 pandemic-related funding, including money from the Provider Relief Fund.

Additionally, CMS said it is looking to add a line for hospitals to report temporary expansion beds because of COVID-19 on worksheet S-3.

The American Hospital Association (AHA) recently submitted comments to CMS about the proposed changes, urging the agency “to do a thorough review and simplify and/or eliminate its requirements to the greatest extent possible.”

“The AHA appreciates CMS’ efforts to improve the quality of the data being reported and eliminate the collection of outdated information,” the hospital group said in the letter addressed to then-CMS Administrator Seema Verma. “However, we have substantial concerns that many of the proposed changes increase hospitals’ regulatory burden, without benefit.”

Among the AHA’s concerns is the introduction of the new worksheet S-12, which the group said CMS did not “provide sufficient guidance” to enable hospitals to report median payer-specific negotiated rates “consistently and accurately.”

“The S-12 is a brand-new worksheet, which requests incredibly difficult-to-calculate data points. Hospitals have many questions that they need to have answered before they can accurately provide the data required,” the letter stated.

Additionally, AHA called on CMS to clarify changes to the S-10 worksheet, which documents hospital uncompensated care data. The hospital group asked for more clarification about reporting instructions, particularly on whether hospitals can qualify individuals for financial assistance or charity care using presumptive eligibility tools, to reduce the reporting burden on hosptials.