2014 DSH / DY 3 UC Payment Timelines & The DY 4 Tool

An Overview of The Upcoming Payment Timelines and and

Changes to The Tool for DY 4

HHSC DSH/UC Organization

HHSC has several staff members who work on various aspects of the DSH and UC programs:• Pam McDonald- Director of Rate Analysis• Selvadas Govind- Director of Hospital Rate Analysis• Rene Cantu- DSH and UC Team Lead• Valerie Lesak- DSH/UC Support Staff, DSH/UC Audit and

Reconciliation Oversight • Doneshia Ates- DSH/UC Support Staff. Works on policy and reviews

Tools• Kevin Niemeyer, Leslie Cisneros- Staff reviewing Tools• Mance Fine- DSH/UC Support Staff. Monitors the UC Mailbox for

tool related questions, works on policy and reviews Tools• Rhonda Hites- Handles all DSH/UC payment related issues and

1115 waiver affiliation certifications and agreements. Rhonda does not work on Tools.

DSH/UC Resource Mailbox

• The UC Tools Mailbox (uctools@hhsc.state.tx.us) is for any DSH and UC Tool, program, or data related questions. Going forward, please do not send DSH/UC payment related questions to this mailbox.

• The DSH Payments Mailbox (DSHPayments@hhsc.state.tx.us) is for all DSH payment related questions and submissions, including the DSH Attestations.

• The UC Payments Mailbox (RAD_UC_Payments@hhsc.state.tx.us) is the new mailbox for all UC payment related issues. Please send all affiliation agreements, IGT commitment forms, and trace sheets for all future UC payments to this mailbox.

Status of the Tools

• HHSC has recently completed the process of reviewing tools. We have asked several providers to clarify information on their applications. We generally ask that providers respond to clarification requests within three days. However, a number of these providers have not yet responded. If you are one of these providers or are unsure of your tools status, then please contact us at uctools@hhsc.state.tx.us.

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Changes to Medicaid Data in the Tools

HHSC has made several changes to the completed tools after they were submitted by the providers. Those changes were:

Amending days, charges, and payments as the result of the provider appeal process.

A number of hospitals have suggested that the allowable outpatient charges adjustment (1 TAC §355.8061 (b)(1)) should not be applied in the calculation of the HSL as these represent allowable costs. HHSC agrees with this suggestion. HHSC is therefore adjusting the outpatient charge amounts back to 100% of the charges for allowable services.

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Changes to Medicaid Data in the Tools

HHSC has made several changes to the completed tools after they were submitted by the providers. Those changes were:

Creating a third HSL tab to calculate the HSL without the inclusion of third party insurance payments. We decided to do so pending the outcome of current litigation between Texas Children’s Hospital/Seattle Children’s Hospital and CMS.

Fixing a formula error in cells K:43 and N:122 of the Sched3-Cost Rept Hospital Costs tab.

Almost all of the changes resulted in an increase in HSL’s. A handful of providers HSL’s decreased as a result of positive adjustments that were made to their Medicaid payment amounts.

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Changes to Medicaid Data in the Tools

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Provider Notification of Final HSL Data

In late March, HHSC will send a spreadsheet to the industry containing all of the revised data points used in the calculation of the HSL and Schedules 1 and 2 so that providers can review any changes that occurred. If, after seeing this spreadsheet, you would like to review your hospitals final tool, simply email the UC Tools mailbox and request a copy of your final tool. The additional data has been kept separate in the green Sched3-prepopdata tab so that providers can see the exact amount added to their Medicaid charges, days, and payments. 11

DSH Qualification 

HHSC will send out DSH qualification notices in early April, 2015 to the email address provided when the tools were requested. Providers that qualify will need to ensure they are in compliance with the conditions of participation (2 physician requirement and being in active pursuit of a Trauma designation) found in 1 TAC §355.8065 in order to receive payments.

The process for the DSH program is much different than previous years. Historically, providers would submit their DSH survey and then

HHSC would calculate HSL’s and DSH qualification and notify providers of their status. Providers would then be given the opportunity to appeal the Medicaid days, charges, and payments that calculated the HSL and DSH qualification thresholds.

For 2014, HHSC sent out the Tools with the pre-populated data in mid-August, 2014. Pursuant to 1 TAC §355.8066 (e)(2)(B), hospitals were given a 30 day appeal period from the date they received their pre-populated Medicaid data in the Sched3-HSL tab of their tool. Since all providers have been given the opportunity to appeal the Medicaid data used in the HSL calculation and DSH qualification, the 2014 DSH qualification determinations will be final.

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Final DSH and UC Payment Dates

Current litigation between Texas Children’s Hospital and Seattle Children’s Hospital and CMS has resulted in a preliminary injunction against CMS enforcing its policy regarding including third party insurance payments in the HSL calculation, HHSC will hold back a percentage of the funds for both of the final DSH and UC payments until the issue is resolved. The percentage being held back will correlate to the effect of such third party insurance payments on HSLs. We therefore anticipate that another DSH payment will be made after the court case is resolved. As indicated earlier, HHSC has created a new tab in the application tool to calculate an HSL without the inclusion of third party insurance (secondary (non billed) + other insurance in the Tool) payments to determine the figure to hold back. 13

DSH/UC Payment Timeline

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UC IGT Notification May 22, 2015UC IGT Settlement Date June 5, 2015

Payment Voucher to Accounting June 12, 2015UC Transferring Paid June 19, 2015UC Non-Transferring Paid June 30, 2015

DSH IGT Notification April 27, 2015DSH IGT Settlement Date May 4, 2015

Payment Voucher to Accounting May 8, 2015

DSH Transferring Paid May 15, 2015

DSH Non-Transferring Paid May 29, 2015

Note: “Transferring” entities are Parkland, Ector County, UMC El Paso, Harris County, JPS/Tarrant County, Lubbock/UMC, UMC Brackenridge, and Bexar County/University Health System.

DSH/UC Attestation Forms

Attestations for the handful of providers that can elect to be treated as a public or private hospital for DSH and UC payment purposes are due to HHSC by Monday, April 6th. All forms must be sent to DSHPayments@hhsc.state.tx.us. Providers that requested to participate in DSH were sent these forms in October, 2014 with the advance DSH payment notification. HHSC will send the forms again to providers with the final HSL data spreadsheet in mid-March.

Attestations were sent to providers in October of 2014 with the advance DSH payment notification.

Unlike prior DSH program years, beginning with DSH program year 2014, all public hospitals will be required to transfer funds to HHSC in order to receive a program year 2014 DSH payment. Urban public hospitals are required to transfer 100 percent of the non-federal share of their Pass One and Pass Two 2014 DSH payments and non-urban public hospitals are required to transfer 50 percent of the non-federal share of their Pass One and Pass Two 2014 DSH

payments.

DSH/UC Attestation Forms

Urban public hospitals (i.e., those owned by a governmental entity that has historically funded DSH payments) do not need to do anything prior to transferring funds into TexNet.

Non-urban public hospitals may need to take certain steps. A non-urban public hospital is:

• Any hospital anywhere in the state that is owned and operated by a non-state governmental entity (other than a governmental entity that has historically funded the DSH program); or

• A privately-operated hospital operating under a lease from a governmental entity in which the hospital and governmental entity are both located in the same county with 500,000 or fewer persons, based on the most recent decennial census, where the hospital and governmental entity have both signed an attestation that they wish the hospital to be treated as a public hospital for all purposes for 2014 DSH and 2014 UC waiver payments. Hospitals in this category are “rural public-financed hospitals” and are eligible, along with rural public hospitals, for Pass Three DSH payments.

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DSH/UC Attestation Forms

• To be designated as a rural public-financed hospital for the May payment, the hospital and governmental entity must execute the attached attestation form and submit it to no later than April 6, 2015.

• A hospital that otherwise meets the definition but does not submit the attestation form by April 6th will be treated as a private hospital for the May payment.

All non-urban public hospitals should ensure that the governmental entity that owns the hospital is aware of its obligation and prepared to transfer funds for the May payment. Any governmental entity that has not previously transferred funds through the TexNet System for an HHSC Payment (i.e., Uncompensated Care, DSH, and DSRIP) must enroll with TexNet to submit funds for this payment. The TexNet Enrollment form can be accessed at http://www.window.state.tx.us/taxinfo/taxforms/89-103.pdf

DSH/UC Attestation Forms

Private hospitals (i.e., privately-operated hospitals that do not lease from a governmental entity and hospitals described in item 2 above that do not submit an attestation form) do not need to do anything to receive the May DSH payment.

DSH/UC Payment Deadlines

All affiliation agreements for UC payments must be submitted by COB Tuesday, May 5th, 2015.

If you are a UC provider and have not yet submitted your Category 4 reporting certification and learning collaborative certification you will need to do so by COB Tuesday, May 5th, 2015. You will not receive a payment until HHSC has received these documents. If you are unaware of these requirements, please reference the reporting requirements for UC participants in 1 TAC §355.8201 (k).

UC IGT Commitments

IGT commitment forms will be due for UC payments sometime around May 15, 2015.

Providers will receive the forms on or around Wednesday, May 6, 2015.

Once the IGT commitments are submitted for the June DY3 UC payment, there will be no last minute additions or substitutions. Please be certain of your funding prior to submitting your IGT commitment form.

You must submit an IGT commitment form, even if you are IGT'ing for yourself.

Please note that for all future UC payment issues that there will be a separate mailbox to contact: RAD_UC_Payments@hhsc.state.tx.us

Providers will receive their June UC amounts when the IGT notifications are sent on May 22, 2015. 20

2012 DSH Audit/ DY 1 UC Reconciliation

2012 DSH Audit• Myers and Stauffer are contracted to complete the audit. HHSC is

working with them on their data requests.

DY 1 UC Reconciliation• Interim Uncompensated Care reconciliations are being completed by

HHSC using the data from the DY 3 UC tool.• Expect interim Uncompensated Care reconciliations to be completed by

March 31, 2015.• Overpayments will be identified by June 30, 2015 and recouped within

one year of identification.• The final Uncompensated Care reconciliations will be performed in

conjunction with each DSH audit starting with DY 1/FFY2012. Reconciliations will be completed by February 28, 2016 for hospitals that have finalized Medicare cost report(s) at the beginning of each audit. This process will continue each year until all reconciliations have been finalized for a demonstration year. Recoupment notices will be sent to hospitals by March 31, 2016 with collections made by February 28,2017.

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Methodology Clarifications

HHSC is working to clarify several issues brought up by providers over the course of DY 2 and DY 3 DSH and UC that we hope to have resolved for DY 4. If providers have any additional methodology-related questions, please send them to the UC Tools mailbox ASAP. The issues being researched include:

The inclusion of costs in excess of the RCE limits used when calculating the cost to charge ratios used in the HSL calculation. Note that regardless of the decision to include these costs in the HSL calculation, any cost in excess of an RCE will never be allowed in Schedule 1.

A final determination on the specifics of allowable costs in Schedule 1, and what form of support is required to claim these costs. Specifically RHC’s, free standing clinics, and what costs in worksheets A-8, A-8-1, A-8-2 are allowable and how they can be claimed.

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Plan for DY 4 Tools

HHSC is attempting to expedite the processing of the DY 4 tools in order to “catch up”, as we are aware that providers need to receive timely payments to help with cash flow. We would like to receive provider input on the changes that we plan on implementing to make our processes more efficient and shorten the time required to review applications for DSH and UC payments. The changes are:

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Plan for DY 4 Tools

Pre-populating the Cost Report Collection tab with cost report (HCRIS Data). Prepopulating the data would save providers the effort of populating this tab and making copies of the cost reports for HHSC. Instead, providers just need to verify the HCRIS data reflects the latest cost reports filed with Medicare Administrative Contractor. This is because HCRIS is updated on a quarterly basis and might not capture the latest cost report.

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Plan for DY 4 Tools

A significant factor in the turnaround time of the tools is that providers need sufficient time to populate the Cost Report Collection tab, and HHSC needs sufficient time to review the providers’ work and make sure that no data was entered erroneously. By populating this tab with the latest data-year cost report in the MMIS system, a good amount of time could be saved because providers would be able to certify that the data was correct, and there would be no review time needed. HHSC would provide a tab in the tool for providers to request any corrections to the HCRIS data. Changes would be flagged and HHSC would then need to only review flagged changes, which would decrease the turnaround time of completing and review of the applications.

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Plan for DY 4 Tools

We will also be linking the allocation statistics for Schedule 1 with the charges in the Cost Report Collection tab, as well as the various allocated charges in the Cost Rept. Hospital Costs tab. This would save a great deal of time because providers would only have to fill out column 1 based on their w/s A-8 and A-8-2. This would also greatly reduce the time needed for review. Providers who wish to use physician charges as an allocation statistic would be treated on a case-by-case basis, but we have noticed in our reviews that the overwhelming majority of providers completing Schedule 1 use the allocated hospital charges from the Cost Rept Hospital Costs tab.

Submitting the Tool to HHSC

Plan for DY 4 Tools

By HHSC pre-populating these fields, providers would have to review the HHSC pre-populated data, notify HHSC of any changes to that data, via a form at the beginning of the tool, and complete column 1 of Schedule 1, the adjustment summary tab, and Schedule 2. In turn, HHSC would review these four items, which would drastically reduce the tool turnaround time.

Plan for DY 4 Tools

Going from an Excel-based Tool to a web-based Tool HHSC is attempting to transition the Tools from an Excel-based

application to an online Tool that can be accessed, completed, and submitted via the internet.

This tool would be prepopulated as mentioned above, and would have the similar functionality as the current Excel-based tool.

Providers would only need to submit their data and would then be able to view their calculated costs (prior to HHSC review and program cap reductions) in the summary tab.

Providers would still have to submit all supporting documentation and the signed certification to the UC Tools mailbox.

This process would expedite tool processing and turnaround time, as the calculated costs and data points needed for program calculation could be gathered quickly.

TXPUC providers would still complete the Excel based tool and submit it as they have in the past.

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Tentative 2015 DSH/DY 4 UC Tool Release Timeline

• HHSC will ask for providers to request participation in the 2015/DY 4 Tools in May, 2015

• The tools will be made available to providers in late June, 2015

• HHSC is hopeful that having 90% of the data used for the tool pre-populated will greatly expedite the turnaround time of the tools.

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Thank You Providers!

The DSH/UC team would like to thank all of the providers and consultants for taking the time to participate in this webinar. We hope to continue these webinars quarterly to increase transparency and to encourage an open line of communication between our team at HHSC and all providers. We believe that all of us are working towards the same goal, which is to ensure that providers receive fair, accurate, and timely supplemental payments for the uncompensated costs that they have incurred. We at HHSC look forward to the continued growth of our relationships with all providers, and hope that we can work together to continue to streamline our processes. Thank you!

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Q & A

Please call in now with any questions or comments. The computer microphone feature unfortunately does not work.To use your phone, you must select "Use Telephone" after joining the webinar and call in using the numbers below. Toll: +1 (562) 247-8421Access Code: 889-656-164Audio PIN: Shown after joining the webinar

Should you be unable to reach us with your comments or have additional questions or remarks after the webinar is concluded, please email your inquiries to uctools@hhsc.state.tx.us.

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