NAHC Submits Comments to CMS on Proposed Home Health Cost Report Changes

Posted on Monday, July 1, 2019 12:09 PM

NAHC and the Home Health Financial Managers Association (HHFMA) have collectively supplied comments to CMS on the proposed changes to the home health cost report and cost reporting instructions.  Here are their recommendations:

  • Requested the effective date be six months after the cost report changes and instructions have been finalized, rather than the proposed January 1, 2020 effective date.
  • Recommend CMS permit the agency’s designated “Authorized Official” to sign the cost report rather than limit the signature requirement to the agency’s Chief Financial Officer or the Administrator
  • Recommend CMS modify the instructions for Worksheet S-3, Part I to clearly indicate how Medicare Advantage and Medicaid Managed Care census statistic should be reported
  • Clarify instructions on Worksheet S-3, Part IV with the implementation of the Patient Driven Grouper Model
  • Highlighted concerns regarding a new worksheet (Worksheet S-3, Part V) which captures salaries, fringe benefits, paid hours, and then computes an average hourly wage by occupational category.
  • Clarify instructions for a new general service cost center for remote patient monitoring and telehealth reporting.
  • Request CMS explain how it plans to use the information reported on Worksheet A-7- Analysis of Changes in Capital Asset Balance.
  • Clarification needed on several cost reporting items regarding home health agencies with HHA-based hospices
  • Recommend CMS maintain Worksheet F-2 (Fund Balance / Equity Rollover) in the revised cost repot
  • Noted inconsistency between Worksheet A and Worksheet O

Source: NAHC Report

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