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Changes to Skilled Nursing Facility Medicare Cost Reports

In 2011, the Centers for Medicare and Medicaid Services (CMS) issued changes to the Provider Reimbursement Manual pertaining to revisions being made to the CMS-2540-10, the Medicare Skilled Nursing Facility and Skilled Nursing Facility Complex Cost Report.  CMS had not made changes to this form since 1996.  These changes are effective for cost reports for years beginning on or after December 1, 2010.

The following summarizes major revisions to the cost reporting forms:

1. The Schedule S, Settlement Summary, has been split into three parts.  Part I summarizes cost report status, Part II is the signer’s certification and Part III is now the settlement summary.
   
   
2. Worksheet S-2, Part I expands the questions that generate other worksheets on the cost report, including questions concerning low-or no-Medicare utilization providers, whether the provider is legally required to carry malpractice insurance, whether the provider carries a claims-made or occurrence malpractice policy and what the liability limits are for the malpractice policy.
   
   
3. Worksheet S-2, Parts II and IV now contains The Provider Cost Report Reimbursement Questionnaire Form CMS-339, which has been brought into the new cost report instead of being a separate document.
   
   
4. Worksheet A, Reclassification and Adjustment of Trial Balance of Expenses, has been redesigned to display a five digit cost center code and includes a new numbering sequence.
   
   
5. Worksheet A-7, Reconciliation of Capital Cost Centers, has added additional information to report a provider’s fully depreciated assets.
   
   
6. Several worksheets have been eliminated including Worksheet A-8-3, Physical Therapy Adjustments, Worksheet A-8-4, Respiratory Therapy Adjustments and Worksheet A-8-5, Other Therapy Adjustments.
   
   
7. In Worksheet D, Parts I-V, columns have been eliminated relating to interns and residents.
   
   
8. There were several changes to the SNF-based home health section of the cost report including Worksheet H-1, Parts I and II, to redesign the allocation of home health agency general service costs.  Worksheet H-3, Parts I and II has been redesigned for the apportionment of patient services costs.
   
   
9. Worksheet H-4, Parts I and II has been re-designated as the settlement summary formally identified as Worksheet H-6.
   
   
10. Worksheet H-5 has been re-designated as the analysis of payments to provider-based HHAs, formally identified as Worksheet H-7.
    
    
11. If a nursing home has a SNF-based Federally Qualified Health Center (FQHC) then the facility should take note of changes to Worksheet I-2, as it is requesting additional information pertaining to personnel.

In December 2011, CMS issued transmittal #3 to incorporate a revision required by “The Patient Protection And Affordable Care Act” (ACA), Section 6104 (“Reporting of Direct Care Expenditures”), for Skilled Nursing Facility And Skilled Nursing Facility Complex Cost Reports Form CMS-2540-10.  This section out of the ACA requires SNFs to separately report expenditures for wages and benefits for direct care staff, breaking out registered nurses, licensed professional nurses, certified nurse assistants and other medical and therapy staff, at the minimum.  This section will be applicable for cost reporting periods beginning on or after January 1, 2012, or calendar year 2012 for most skilled nursing facilities.

You will note that a lot of changes described above are to reorganize the cost reports or to collect information previously collected in different sections of the cost report.  However, there are a few things that will be new including the collection of information concerning malpractice insurance and some wage index related information.

Be on the lookout for additional questions from your cost report preparer as this information will begin to be included in cost reports in time for the filing deadline of May 31, 2012.

If you need assistance or have any questions, please contact the Feeley & Driscoll healthcare group by email or call 1 (888) 875-9770.

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