Reply to Comments

Comment
We received comments that the Instructions for Worksheet S Part 1,
Line 4, Column 1, note that a provider must receive contractor
approval prior to submitting a low utilization and reference CMS Pub.
15-2, chapter 1, §110. This manual section also addresses
requirements for the filing of a No utilization statement. Those
requirements should also be included in the line 4 instructions.

2 We received comments that the Instructions for Worksheet S Part 1,
line 10, column 3, indicate that an NPR date will only be required
where the cost report status is 2 (settled without audit) or 3 (settled
with audit). An NPR is also required when the status is 4
(Reopened).

Response
We appreciate the commenter's suggestion and edited Worksheet S Part 1, Line 4, Column
1, to read, "Enter an “F” if this is full cost report, an “L” for a low Medicare utilization cost
report or an “N” for no Medicare utilization. A provider that has not furnished any covered
services to Medicare beneficiaries during the entire cost report period may file a no
Medicare utilization cost report in accordance with CMS Pub. 15-2, chapter 1, §110(A).
Providers must obtain contractor approval prior to submitting a low Medicare utilization cost
report. (See CMS Pub. 15-2, chapter 1, §110(B).)"
We appreciate the commenters suggestion and have edited the Instructions for Worksheet
S Part 1, Line 10, Column 3 to read, "Enter the Notice of Program Reimbursement (NPR)
date (mm/dd/yyyy). The NPR date must be present if the cost report status code is 2, 3, or
4."

3 We received comments that the Instructions for Worksheet S-1, Part We appreciate the commenters suggestion and have modified the instructions for
II, Column 2 currently requires the reporting of “Other” patient visits Worksheet S-1, Part II, columns 2 through 6.
and column 5 requires “Other” patient days. Commenters noted
these columns are then added to Medicare statistics to calculate the
total. This treatment has caused difficulties with subsequent audits
and revisions to Medicare statistics. Technically if the Medicare
statistics are updates for subsequently paid claims the “other”
columns also require an adjustment if there has been no change in
the total statistics. Can the reporting of other statistics be
eliminated? It could be imputed by subtracting Medicare from the
total statistics for data analysis.
4 Commenters noted that the Instructions for Worksheet S-2, Line 1
have been confusing to some providers on other form sets. Are you
asking if this is the first cost report being filed by the new owner, or
are you asking if there was a change of ownership within a cost
reporting period?
5 Commenters noted that the bad debt listing required in the
instructions to S-2, Line 6, that while internal schedules for the bad
debt listing can be used, that schedules must also contain at least
the detail of the Exhibit 1. Commenters suggest If that is that case
that should be specified in the instructions.

The intent of the question is to identify the first cost report being filed by the new owner.
Clarified the instructions for Worksheet S-2, line 1.

The Instructions for Worksheet S-2, Line 6, state, "Indicate whether you are seeking
reimbursement for bad debts resulting from Medicare deductible and/or coinsurance
amounts which are uncollectible from Medicare beneficiaries. (See 42 CFR 413.89(e) and
CMS Pub. 15-1, chapter 3, §§306 through 324 for the criteria for an allowable bad debt.)
Enter “Y” for yes or “N” for no in column 1. We clarified the remainder of the instruction to
read as follows: If you answer “Y” in column 1, submit a completed Exhibit 1, or internal
schedules that at a minimum duplicate the documentation requested on Exhibit 1, to support
the bad debts claimed.

Comment
6 Commenters suggested that the Instructions for S-2, Line 9, require
a crosswalk between revenue codes and charges found on the
PS&R to the cost center groupings on the cost report. Can you
specify that the crosswalk should report the groupings to the cost
centers listed on Worksheet C?
7 Commenters noted that the fourth and seventh paragraphs in the
Instructions to Worksheet A are duplicates.

Response
We have clarified the instructions for Worksheet S-2, lines 9 and 10 and requested that the
provider submit a crosswalk between revenue codes and charges found on the PS&R to the
cost center groupings on Worksheet C of the cost report.
We have deleted the duplicate paragraph in the Instructions for Worksheet A.

8 Is it CMS’s intent that all contracted costs would be reported in
We appreciate the commenter's suggestion and have modified Worksheet A and the cost
column 2 of Worksheet A? If so this should be specified and this has report instructions to identify all contracted and purchased service costs in a newly added
been clarified in the instructions to the 2552-10.
column 3.

9 Commenters noted that the instructions to Worksheet D, line 10,
reference cost reporting periods beginning on or after October 1,
2014. It is probable that all cost reports filed on Form 2088-17 will
have a cost reporting period beginning after October 1, 2014.

Agree and removed the reference to cost reporting periods beginning on or after October 1,
2014.

10 Commenters asked if it would be appropriate to add a line to
Worksheet D for Pioneer ACO demonstration payment adjustment
amounts?
11 Commenters noted that on Worksheet D-1 there is a bold note that
states that lines 5-7 should only be completed by the contractor. On
the 2552-10 this note was modified to state that providers can
complete this line for amended cost reports.

We modified the instructions to include a more general line for the demonstration payment
adjustments.
We appreciate the commenter's suggestion and edited the bolded note in Worksheet D-1 to
read, "DO NOT COMPLETE THE REMAINDER OF WORKSHEET D-1. LINES 5
THROUGH 7 ARE FOR CONTRACTOR USE ONLY. (EXCEPTION: IF WORKSHEET S,
PART I, LINE 5, IS “5” (AMENDED COST REPORT), THE PROVIDER MAY COMPLETE
THIS SECTION.)"