NAVEOS®’ Commentary on the 2018 Hospital Inpatient PPS Proposed Rule

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NAVEOS®, the proven leader in maximizing the value of governmental program reimbursements for healthcare providers, offers commentary on the Medicare DSH component in the 2018 IPPS Proposed Rule changes.

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Hospitals must prepare for the transition to WS10 so that their uncompensated care payments aren’t impacted and they can continue caring for low-income populations. Those that prepare will benefit at the expense of those that don’t.

On April 14, 2017, the Center for Medicare & Medicaid Services (CMS) announced that the Uncompensated Care Pool (UCP) calculation for Medicare Disproportionate Share Hospitals (DSH) will transition away from the Days Proxy method to Worksheet S-10 (WS10), Line 30 (non-Medicare UCC) much sooner than previously communicated. The announcement was part of the federal fiscal year (FFY) 2018 Proposed Rule released on the CMS website.

Under the Proposed Rule, CMS will begin using WS10 to determine uncompensated care payments and distribution beginning in FFY 2018. Accelerated adoption of WS10 will have major implications not only on the DSH providers receiving uncompensated care payments but also on the low-income communities they serve. Many disproportionate share hospitals rely on uncompensated care payments to serve low-income patients and any modification to these payments may ultimately impact care.

Not adequately preparing for the upcoming transition may have potentially devastating consequences on DSH providers and their low-income patient populations. Below is a brief outline of our suggestions on how to best prepare for the transition:

  • Hospitals should review their Charity Care, Bad Debt, and other WS10 related policies to make sure these write-offs (i) correspond to the hospital’s policies and (ii) conform to WS10 instructions per Transmittal 10 (CMS revised the Charity Care definition in Transmittal 10. Charity Care will now be based on hospitals’ “date of charity care write-off” as opposed to “dates of service”).
  • Hospitals should amend their WS10 filings (2015 & 2016 WS10 should be amended to reflect the revised Charity Care definition)
  • Hospitals should amend their 2013 Low-Income Days


Hospitals must prepare for the upcoming transition to WS10 to ensure that their uncompensated care payments aren’t materially impacted and they can continue providing quality care to low-income populations. All DSH hospitals are effectively competing for a fixed pool of Federal DSH UCP dollars so those that prepare adequately will benefit at the expense of those that do not. (The total UCP and DSH pool will decline from $12.5 billion in FFY ‘14 to $10.96 billion in FFY ‘18.) At a minimum, hospitals should perform a policy review to ensure that their policies and procedures will support WS10.

NAVEOS is a healthcare data analytics provider that has developed proprietary software that ensures hospitals can accurately claim the federal DSH UCP dollars they deserve. NAVEOS’ software solution COMPASS is able to analyze complex inpatient and outpatient, sub-claim level data to help clients nationwide recover additional funds owed to them. In applying COMPASS to clients’ data sets, NAVEOS typically finds 2% - 6% in unclaimed value. Over the years, NAVEOS has found an aggregate of nearly $1 billion in additional DSH / 340B payments for its clients.


NAVEOS is the proven leader in maximizing the value of governmental program reimbursements for healthcare providers. Since 2005, our superior approach to data analytics has enabled healthcare providers to receive the maximum value possible in DSH / 340B reimbursement payments.

NAVEOS has developed a fully integrated DSH / 340B software solution with a national eligibility verification network for both Medicare and Medicaid data. This system, which is the most robust in the industry, uses sophisticated algorithms to match eligibility data with patient data, applies the most up to date federal and state regulatory parameters, then builds comprehensive deliverables for supporting DSH/340B filings. By leveraging our state-of-the-art technology and unsurpassed domain expertise, we generate best-in-class deliverables that yield impressive value and achieve a stellar (99.7%) audit acceptance rate.

Our unparalleled results typically yield 2% - 6% more Medicaid patient days and often:

  • Allow healthcare providers to attain DSH/340B qualification;
  • Keep healthcare providers from falling out of DSH/340B; and,
  • Result in additional DSH reimbursement when following another vendor

Questions can be directed to NAVEOS at info(at)naveosdata(dot)com or (888)550-2708.

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