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2015 Medicare Cost Report Update for FQHC Providers


3/24/16

As required by the Affordable Care Act, the Centers for Medicare and Medicaid Services (CMS) has recently obtained approval from the Office of Management and Budget (OMB) for the new Federally Qualified Health Center Cost Report Form (CMS-224-14). This new form replaces the existing Form CMS-222-92 for FQHCs only. It is expected that the Office of Strategic Operations and Regulatory Affairs (OSORA) will publish and make available the new cost report in April 2016. Cost report vendors are now going through the approval process, and it is expected that vendors will be approved concurrent with the cost report being published.
 
The new Form CMS-224-14 reflects major changes to the report from the old Form CMS 222-92. These changes include the following:

  1. Worksheet S will now incorporate questions originally included in the Q-339 Questionnaire, including newly added questions relating to medical malpractice and capital related costs.
  2. Contract labor, benefit costs and employee data for providers will need to be reported on the new Worksheet S-3.
  3. Cost centers on Worksheet A were modified and condensed.
  4. Elimination of the productivity standards and the mental health limitation on Worksheet B
  5. Worksheet B is revised to reflect the payment policy under the new FQHC Prospective Payment System (PPS) and now includes the reporting of costs and visits by types of billable providers
  6. A new Worksheet F-1 was added which will capture the revenues and the expenses of the FQHC to provide estimates of total facility and Medicare margins that are used in payment update activities and discussions with Medicare Payment Advisory Commission (MedPAC)
     

CMS extensions for the currently delayed cost report submissions should be announced when the cost report is published and released. It is possible that CMS can make an earlier announcement.
 
What Does CohnReznick Think?
Form CMS-224-14 includes a variety of new information that will be required to be reported as mentioned above. The new cost report is set to be published in April 2016, and is not significantly different from the original draft cost report which is currently available on the CMS website. FQHCs should begin to review and familiarize themselves with the new changes, read the instructions to the draft cost report (available on CMS website) and start gathering the data necessary, in order to factor in the extra time that will be required in preparing the new cost report. (CMS has estimated approximately 16% more hours for completion of this report based on the changes.) It is imperative to make sure that Form CMS-224-14 is prepared accurately as certain information from the report will be utilized in developing a new trend factor “market basket” for the FQHC Medicare base rate. There will also be certain data used to provide estimates of total facility and Medicare margins that are used in payment update activities and discussions with Medicare Payment Advisory Commission (MedPAC). Now is the time to assess if you need assistance with the report to ensure it is prepared properly and in accordance with the new requirements. Stay tuned for CohnReznick’s 2015 Medicare Cost Report Webinar shortly after the CMS 224-14 report is officially released.
 
Contact
 
For more information, please contact Steven Schwartz, a Partner in CohnReznick’s Healthcare Industry Practice, at steven.schwartz@cohnreznick.com or 646-254-7484.


This has been prepared for information purposes and general guidance only and does not constitute professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is made as to the accuracy or completeness of the information contained in this publication, and CohnReznick LLP, its members, employees and agents accept no liability, and disclaim all responsibility, for the consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it.

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