Wage Index Issues

Hello, my name is Kendall Quisenberry and I am the President of Reimbursement Counselors. Welcome to the second entry into my Reimbursement Blog!

Periodically, I hope to provide you with key insights, tips, and little nuggets of information you can use to help your facility achieve its goals. We invite you to take a moment and subscribe to the blog through the link at the bottom of this page.

This entry is important because it will inform you of important dates for the FFY 2009 wage index and other recent wage index related developments.

CMS Posts FFY 2009 Wage Index Development Time Table

On October 9, 2007, CMS posted the FFY 2009 Wage Index Development Time Table on their website. The preliminary wage data files were released on October 5, 2007. The most important date on the Time Table from a hospital manager’s prospective is December 7, 2007. This is the deadline for hospitals to submit requests for a revision to their Worksheet S-3 wage data. The request for revision must be accompanied by documentation to support each requested revision. FI’s will be allowed until February 13, 2008 to complete all desk reviews for wage data and transmit the revised data to CMS.

If your facility has not begun the process of reviewing its wage index data or engaged an outside consultant to do so, now is the time to act. This is particularly important for hospitals that make up a significant portion of their CBSA and are reimbursed based upon a prospective rate, but the effect of the wage index should not be underestimated by any hospital adminstrator. Small adjustments to the wage data can produce large swings in the amount of Medicare reimbursement ultimately received.

CMS Includes Additional Contract Labor in Wage Index

The FFY 2008 Final Rule was published on August 22, 2007. The Final Rule stated that contract labor for Administrative & General, Dietary, Housekeeping and management contracts would be included in the FFY 2008 wage index. Since this data has been included in the FFY 2008 wage index, hospital administrator’s should ensure Worksheet S-3, Part II, Line 9.03, 22.01, 26.01 and 27.01 are properly completed for the FFY 2009 wage index.

While the inclusion of Dietary and Housekeeping contract labor may actually decrease a facility’s average hourly rate, the Administrative & General and management contracts have the potential to increase the average hourly rate significantly. In any event, the goal should be to get it right (i.e. compliant) regardless of the impact. For those facilities with current management contracts in place, steps should be taken to ensure the the number of labor hours that are associated with the payments can be identified. If the hours cannot be identified, the hospital should make changes to the contract or billing procedures to ensure that the hours can be identified for future periods. If the hours cannot be identified, the payments will not be able to be included in the wage index. Another proactive step that should be considered by management is to implement an electronic method to accumulate contract labor hours throughout the fiscal year. This can save hours of your staff’s time or reduce the amount of consulting fees paid.

I hope this and all future blog entries help you identify the most important of reimbursement issues and new developments in the field for you.

Sincerely,

Kendall Quisenberry
President
Reimbursement Counselors

(972) 403-9910

 

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