On May 8, 2020, CMS released the FY 2022 Hospital Wage Index Development Timetable. The timetable indicates that the preliminary FY 2022 Worksheet S-3, Parts II and III wage index Public Use File (“PUF”) will be released on May 18, 2020. The PUF will contain wage data based on FFY 2018 hospital cost reports – that is, cost reports with fiscal year begin dates of on or after October 1, 2017 and on or before September 30, 2018. The FFY 2018 wage data will be used in the development of the proposed FFY 2022 wage index to be published in the Federal Register in the spring of 2021.
It is important to note that the PUF excludes hospitals designated as critical access hospitals as of May 2020. The PUF will be available here.
The wage index is a major component of both inpatient and outpatient hospital payments (impacting at least 60 percent of the payment). So it is important that hospitals confirm the accuracy of their data in the PUF. Hospitals may request revisions to their preliminary wage index data if there are any issues.
The FFY 2022 Hospital Wage Index Development Timetable indicates that all requests from hospitals for changes to their FFY 2022 wage index data must be submitted to and received by their Medicare Administrative Contractors (“MACs”) by September 3, 2020. Note that 2019 occupational mix data, which is collected every three years and is used in the wage index calculation, must be submitted by August 3, 2020. Revisions to occupational mix data are also due by September 3, 2020. A hospital that wishes to revise its data must submit its request along with complete, appropriate, detailed supporting documentation to its MAC. MACs must receive the revision requests and supporting documentation by this date.
Practical Takeaways
- The FFY 2022 PUF will be used to calculate the wage indices used for hospital inpatient services between October 1, 2021 and September 30, 2022 and outpatient services between January 1, 2022 and December 31, 2022.
- This data will also be used to set the wage indices for other providers – e.g., hospice, skilled nursing facility, IPPS-excluded hospitals.
- Hospitals should carefully review the PUF to confirm the inclusion and accuracy of their wage index data. Hospitals should also review if there are any significant changes to specific categories of costs or hours from last year and investigate whether those changes are appropriate.
- CMS has very specific deadlines to request revisions. CMS has already postponed the reporting of occupational mix data. So hospitals should monitor these timelines and submit data, revisions and/or supporting documentation by the appropriate due dates.
If you have any questions, please contact one of the following professionals:
- Joseph Krause at (414) 721-0906 or jkrause@novacompliance.com;
- David Snow at (303) 801-3536 or dsnow@novacompliance.com;
- Lori Wink at (414) 721-0456 or lwink@novacompliance.com; or
- Your regular Hall Render attorney.
Hall Render blog posts and articles are intended for informational purposes only. For ethical reasons, Hall Render attorneys cannot—outside of an attorney-client relationship—answer specific questions that would be legal advice.
