February 01, 2018

Worksheet S-10 and Hospitals’ Uncompensated Care: A Moving Target That Is More Important Than Ever

Mark Polston and Elizabeth Swayne, King & Spalding, LLP, Washington, DC

Long-threatened in preamble language,1 the Centers for Medicare & Medicaid Services (CMS) has finally begun to include cost report Worksheet S-10 data in the calculation of hospitals’ Uncompensated Care (UCC) pool payments.  Although Worksheet S-10 data only makes up one-third of the calculation of an individual hospital’s UCC payments in fiscal year (FY) 2018, by FY 2020 it is expected to account for 100 percent, and hospitals are wise to ensure that they are fully capturing their allotted share of a multi-billion dollar pie.2  Many hospitals have questions about how best to complete their Worksheet S-10, and CMS has issued several sets of instructions recently to further clarify how to report charity care and bad debt charges.  Most recently, CMS has indicated that in addition to typical charity care, hospitals can also account for care under their financial assistance policies for self-pay patients.  This article explores CMS’s evolving Worksheet S-10 policies and considers how hospitals might best implement and record charges under their charity care and financial assistance policies.

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