T-18 Changes: Medicare Empirical Disproportionate Share (DSH)

Transmittal 18 changes to Medicare Empirical Disproportionate Share (DSH) include the following:

A. Changes to Medicare DSH Schedules and Reporting 

Exhibit 3A – Medicaid Eligible Days for a DSH Eligible Hospital

CMS finalized and released the required template hospitals must use to report their DSH eligible days. The exhibit includes 18 columns to be populated when preparing the DSH eligible days patient listing. For hospitals reporting Medicaid days on Worksheet S-2, Part I, line 24 or 25, a separate exhibit is required for each CCN.   

Toyon’s take

The issuance of Exhibit 3A does not impact or change the structure of the DSH payment. The expectation is that all hospitals across the country will report and file their DSH patient listing in a standard format, allowing the MACs to better standardize their review process. Hospitals will continue to report their Medicaid DSH days under the six different columns on Worksheet S-2, Part I, line 24 or 25. DSH hospitals will submit Exhibit 3A with the Medicare cost report. 

B. Updated Definitions and Clarifications 

DSH Medicaid Eligible Days 

CMS updated the definitions for the reporting of DSH Medicaid eligible and 1115 Waiver days between in-state, out-of-state, HMO and other (Worksheet S-2, Part I, Lines 24 and 25). Worksheet S-2 Line 24 is to report IPPS acute Medicaid days. Line 25 is to report IRF Medicaid days.  

Toyon’s take:  

CMS’s updated definitions are intended to assist hospitals with categorizing Medicaid-eligible patients.    

For further information, please contact Dylan Chinea at (925) 685-9312 or dylan.chinea@toyonassociates.com.