As with DSH Medicaid days, this component of the DSH calculation (i.e., the SSI/Medicare fraction) is and has been, throughout the history of DSH, the subject of many and varied appeals and much litigation. This is partly because hospitals are required to rely on the Medicare/SSI fractions that are provided to them (published) by CMS, but without any means for hospitals to assess the accuracy of the CMS determined/published fraction. With the Medicare Modernization Act of 2003 (2003 MMA), Congress attempted to provide hospitals with a means to assess CMS’s published fractions by directing CMS to “make all needed information available to hospitals, so that they can calculate (re-calculate) their own SSI/Medicare fractions.” Unfortunately, CMS’s response to the 2003 MMA was to merely provide hospitals with the routine use data (RUD) supporting its published SSI/Medicare fractions. While this may have been a small step toward responding to the 2003 MMA, it falls well short of “making information available, so that hospitals can calculate (or re-calculate) their Medicare/SSI fractions.” Consequently, this matter is still a contentious “black box.”
McKay Consulting is a national leader in providing strategic consulting services related to Medicare DSH reimbursement.
DSH SSI/Medicare Fraction
The accuracy of the SSI/Medicare fraction has a significant impact on each hospital’s Medicare DSH reimbursement. Because of the 2003 MMA, hospitals can now request and receive RUD for all years after 2004. Even if this data by itself does not allow the provider to calculate (or recalculate) their SSI/Medicare fractions, it can be used to identify and pin point issues relating to hospital SSI percentages. McKay Consulting works with its provider partners to obtain and store this Medicare SSI RUD.
McKay Consulting reviews of CMS’s SSI RUD have identified errors such as:
- Varied treatment of Medicare beneficiaries who are covered under Medicare Part-C
- Medicare Part-A beneficiaries in the SSI Percentage who are not included on the Medicare PS&R
- Medicare beneficiaries who are receiving SSI benefits but are not treated as such in the SSI Percentage
- The use of incorrect health insurance claim numbers for matching SSI recipients, etc.
In addition to the matters mentioned above, with the RUD, McKay consults with and advises hospitals regarding requests for SSI re-alignment (i.e., receiving its SSI fraction based upon its cost reporting year rather than the Federal year).
Our goal is, and has always been, to provide our clients with the best finance and reimbursement consulting services in compliance with all applicable laws and regulations, while positioning providers for optimal reimbursement.
