Cms-10079 comment #1

March 14, 2007
Centers for Medicare and Medicaid Services
OfJice of Strategic Operations and Regulatory AfSairs
Division of Regulations Development-C
Attention: Ms. Bonnie L. Harkless
Room C4-26-05
7500 Security Boulevard
Baltimore, Maryland 21244-1 850
Dear Ms. Harkless:
The following comments are in response to the proposed rule issued February 2, 2007
regarding occupational mix surveys required to be completed by hospitals reimbursed under
the Medicare Inpatient Prospective Payment System. The proposed rule was issued with the
following Document Identifier: CMS-10079 and CMS-R-245.
Our Firm works closely with healthcare providers through the preparation of cost reports,
reporting of wage index data including data reported on the Occupational Mix Survey (Survey).
We appreciate the opportunity to provide comment regarding the data gathering process for the
occupational mix adjustment to wage index data used in the Medicare rate setting process.
The Medicare wage index and accompanying occupational mix adjustments rely upon
consistent reporting by all participating providers. We believe the consideration of the
following comments would serve to enhance that consistency. Please consider the following
comments regarding the proposed Survey.
Allocatinp Overhead Deuartments
The instructions state that "hospitals should apply the allocation methodology that is used in
the wage index calculation for allocating general service salaries and hours to excluded areas
(See 70 FR 47373, August 12, 2005, Step 4) ". As you are aware, the allocating methodology
described in the 2005 Federal Register is not computed on the actual Medicare cost reporting
forms for acute care hospitals (Form 2252-96). As a result, the calculation may be unfamiliar
to individuals charged with the responsibility of completing the Survey. I f a formal
methodology could be developed and issued to providers through a CMS issued form,
consistency among Survey preparers could be improved.

P.O. BOX 6
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ALBANY, GEORGIA 31702-0006
(229) 883-7878
FAX (229) 435-31 52

PARTNERS:
DOUGLAS E. FAIRCLOTH, CPA
CHARLES WILLIAMS, JR., CPA
J, MILTON J
O R ~cPA
~ ~ ,
LINTON A. HARRIS, CPA
STEPHEN M. BEDSOLE, CPA
CYNTHIA R. DUPREE. CPA
JIM L. CREAMER, SR., CPA
JEFFREY S. WRIGHT. CPA

MILES V. ESPY, SR., CPA
MICHAEL L. REESE, CPA
SANDRA D. CANNON, CPA
WILSON E. JOINER, Ill, CPA
C. BERT BENNElT, CPA
CHARLES R. HORNE. CPA
JlMMlE D. RICHTER, JR. CPA

MEMBERS:
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CERTIFIED PUBLIC ACCOUNTANTS
THE GEORGIASOCIETY OF
CERTIFIED PUBLIC ACCOUNTANTS

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Centersfor Medicare and Medicaid Services
W c e of Strategic Operations and Regulatory AfSairs
Page Two

March 14, 2007

Multi-Discipline Employees
The occupational mix survey requires identification of employees who provide services to IPPS
areas. To the extent services are provided in the routine area of an excluded unit (i.e.,
inpatient rehabilitation), the identification of these employees is not typically readily available.
Dificulties in segregating personnel costs often arise when ancillary services are provided by
one employee (or department) to both IPPS and IPPS-excluded areas. A common example is
the provision of therapy services by one ancillary department. mentimes, the therapy
ancillary department provides services to patients in the inpatient rehabilitation unit and also
to general inpatient and outpatient areas of the hospitals.
For wage data reporting purposes on Worksheet S-3 11, there is no mechanism to segregate
these ancillary services between excluded units and IPPS services. Guidance should be
provided regarding the treatment of this scenario for completion of the Survey.
Home Office, Related Organizations, and General Service Cost Centers
The Survey instructions address the treatment of "employees in the home ofice, related
organizations, or general service cost centers". The instructions are not clear regarding the
amount of home ofice or related organization personnel wages and hours to be reported on the
Survey. For example, it would seem the intent of the Survey would be that wages and hours
reported for home ofice personnel should be reduced in accordance with the percentage
allocated to the hospital. In addition, must the wages and hours paid to personnel employed
by a related organization be reduced to the costs associated with services provided to the
reporting hospital in accordance with cost finding principles applied on the hospital cost report
(CMS 2552-96).
Suvvortin P Documentation
The instructions to the Survey state "it is important for hospitals to ensure that the data
reported on the survey are accurate and verifiable through supporting documentation".
Communication throughout the provider community indicates that many providers and
intermediaries remain unsure what "supporting documentation" would be necessary to support
data reported on the Survey. While it would seem that each provider could make a
determination speczfic to their entity, the consistency desired through the wage index reporting
process requires consistent documentation available for intermediary review. Guidelines
regarding the appropriate methodologies addressing the above allocations and other necessary
calculations should be developed and dissimenated through the Survey instructions. The use of
these guidelines by providers should provide for improved consistency in the documentation
maintained by providers and a stronger basis for consistent interpretation of data and
application of regulations by all providers and their intermediaries.

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Centersfor Medicare and Medicaid Services
Ojjice of Strategic Operations and Regulatory AfSairs
Page Three

March 14, 2007

Again, we appreciate the opportunity to submit these comments regarding the proposed Survey.
We believe that consideration of the above comments will provide for the greatest consistency
throughout the occupational mix data gathering process.
Ifyou have any questions, please contact me at (229) 883-7878.
Sincerely,