Medicare DSH

The legal and analytical discussion of Medicare DSH reimbursement is never a dull moment for cost reporting professionals. Since the early days of HCFA (now CMS) Ruling 97-2, which significantly widened the scope of which types of patients to include in the DSH calculation, countless PRRB Appeals and Federal Circuit Court decisions and remands have constantly shaped - and at times confused, this major budget item.

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Medicom management has been at the forefront of DSH analytics since the initial passing of 97-2, and has actively participated as a State beta tester, cost report audit support preparer and litigation expert witness in this matter. We rigorously work through inpatient eligibility and claims data optimization; fully document and support claims in compliance with CMS audit standards, including government agency eligibility verification, managed care and out of state assistance.

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UPDATE: 

DSH has been significantly expanded under the Affordable Care Act (ACA) to encompass a hospital's Uncompensated Care Payment (UCP). Under the ACA, patient populations being scrutinized for reimbursement now include outpatient in addition to inpatient activity, all non-physician units (i.e. including psych), State indigent programs besides just Medicaid Title 19, and charge/revenue data in addition to days. Enhanced by the expansion of Medicaid for opt-in States, the landscape of DSH/UCP has become a vastly new frontier of both confusion and opportunity - depending on how it's approached. Ominously, ACA legislation pertaining specifically to the UCP-DSH rate tables are not subject to PRRB appeal. Therefore, absent litigation and with time working against them, hospitals are being pressured to update relevant areas of their Medicare cost report, such as Worksheets S-2 and S-10, sooner rather than later to take full advantage of their potential program benefits.