The Centers for Medicare & Medicaid Services (“CMS”) has released the revised Home Health Agency Cost Report, Form CMS-1728-20. The updated Cost Report will be effective for cost reporting periods beginning on or after January 1, 2020 and ending on or after December 31, 2020.
Some of the most notable changes are as follows:
- Reporting visits and census data for LPNs, physical therapy assistants and occupational therapy assistants,
- Reporting financial information for LPNs, physical therapy supervisors and assistants, occupational therapy supervisors and assistants, and speech-language supervisors,
- Reporting average wage data for direct care employed staff,
- Establishment of Telecommunications Technology, Medical Records, and Nursing Administration as General Service Cost Centers,
- Creation of Advertising, Fundraising, and Telehealth as non-reimbursable cost centers, and
- Reporting Medicaid visits and census data, which was previously reported with other non-Medicare patients.
Telecommunication Technology is defined as “remote patient monitoring as described in 42 CFR 409.46(e).” Telecommunication Technology does not include telehealth services, which are reported as non-reimbursable services. Telehealth services are subject to certain criteria.
The following statistics are used for the allocation of the “new” General Service Cost Centers:
- Telecommunications Technology (Accumulated Costs – excluding non-reimbursable activities),
- Nursing Administration – Direct Nursing Hours, and
- Medical Records – Accumulated Costs (selected cost centers).
Home health agencies will need to identify mechanisms to capture costs retroactive to January 1, 2020 for the new cost centers as well as develop a methodology for retroactively capturing direct patient care hours for purposes of allocating Nursing Administration.
It appears that many of the comments on the proposed cost reporting changes were not considered in the determination of the Form CMS-1728-20, especially the retroactive application of the changes. The cost report and instructions are available here.
More information will be provided once the revised cost report and instructions are further assessed. It is anticipated that cost report education will be made available from various sources, focusing on the changes and the information that needs to be accumulated prior to the submission of the new forms. The Health Group, LLC, a NASBA approved sponsor, will be looking at dates for providing upcoming education as well.