Comments_to_CMS_on_Budget_and_Cost_report_proposed_changes_02_2013

Budget
o WS A, Part I, Column 1 - A&G allocation will now be included in each Cost category.
Instructions say to use allocation from Column 5 of WS E, however if adjustments,
including removing non-allowable A&G, were made to A&G in Column 3 of WS E,
won't tie back to Trial balance (WS E, Column 1).
o WS A, Part III, Line 4 - the label should read that the number comes from Line 10
instead of 11.
o Instructions - Clarify how to upload Certification Statement in HPMS. Will the format
be pdf? Will the Excel report be loaded first and then the certification
statement?
o Instructions - WS A, Part II, Column 5, Line 11 - need to keep "minus Lines 13 and
14" in formula
o Crosswalk grid may have some errors in issue #'s referred to in the Changes to
Application and Reason for change columns. e.g. Issue #10 refers to issue #10, but
should it be #9 instead?
Cost Report
o WS E, line 16a was added to split Coinsurance from Deductible and Coinsurance on
claims already paid by the Carrier/Intermediary. Running Coinsurance through
column 6 of WS E to feed WS L, line 18, will allocate some A&G to these services.
Is this change necessary, since WS N, line 8c is pulling directly from WS G, line 23+
line 24?
o WS E, line 19 was added to identify Part B Services not Subject to Coinsurance and
needs to be Medicare only costs in column 6, since it feeds WS L, line 25. Since
these services sometimes are provided by related party, there may be adjustments to
get to allowable costs.
Would it make sense to run these claims for both Medicare and non-Medicare
through WS E, column 6 and then create a separate section of WS K, which uses ratio
of Medicare to Total and applies to total allowable costs to calculate Medicare
allowable labs and covered vaccines. The Medicare costs could then feed WS L.
o There seems to be a formula error on line 21, col 2, WS L which pulls through onto
WS M (it seems to be pulling from the old mental health location on WS K) It

appears the label may be wrong since it says pulling from line 19, but formula links to
line 23.
o

It appears the proposed changes should have included a change to the cost report that
was not made. In WS L, Column 2, Line 22, the Medicare beneficiary payment of
coinsurance on Outpatient Mental Health Treatment limitation was supposed to be
reduced over a 5 year period, per the attached document (“CMS Memo - Outpatient
Mental Health Services Coinsurance”). CMS stated that they would correct this in
their template going forward, but it appears that they have not. The percentage still
remains at 37.5%, and it should be down to 25% for the 2012 cost report (should have
been 31.25% for 2010 and 2011).

o Instructions - There appears to be a typo in the dates on 2303.1 at the bottom of page 6
and top of page 7 of the redlined instructions. We believe that the dates should either
be 2014, 2012, 2012 or 2012, 2010, 2010. I think the rest of the instructions use 2012
and 2010 dates.
o Instructions - The WS N instructions seem to be changing which year budget report the
line 10 amount pulls from. Is this intentional, and if so is there any additional step
that will be taken once these revised instructions go into effect to avoid double
counting a year? There seems to be an inconsistency between the instructions and the
form on this item, so perhaps the year changing is just a typo? E.g. For the 2012
Final Cost report, WS N, line 10 will be over-collection from 2010, however that was
already used in the calculation of 2011 Final Cost report WS N, line 10.
o WS N is confusing since WS N and WS B (from budget) are inter-related. One year
carries over and impacts another, so as one gets finalized and adjusted, it could
change result of the other.
E.g. 2013 Budget, completed in Oct 2012, references WS N from 2011 Final Cost
report. If 2011 Final Cost report gets finalized after 2013 Budget is submitted, could
change over/undercollection calculation.
Perhaps this will be part of CMS’ re-computation process of Over/Under Collections
for Medicare covered services?
There is a significant concern regarding inconsistencies on worksheet N line 10
related to the current instructions and the new ones. When calculating the
Over/Under collection of Premiums there are inconsistencies between how the budget
calculates it vs. worksheet N. The concern is that, if the new budget starts to use the
previous worksheet N totals which are believed to be incorrect due to line 10, this will
create an ongoing issue from year to year.