Proposed Rule Changes to Chart & Cost

As communicated in our e-blast issued October 23, 2009, Howard, Wershbale & Co. (HWCO) submitted comments to the Ohio Department of Job and Family Services (ODJFS) regarding the proposed changes to the Nursing Facility (NF) chart of accounts and cost report. Concerns raised included the lack of clarity in certain account descriptions, inefficiencies in cost report format, and omissions of necessary accounts.   

We are pleased to report that on November 13, 2009, ODJFS responded favorably to all comments submitted by HWCO. Following is an updated version of the October 23, 2009 eblast, reflective of critical changes made at our recommendation. We have included a detailed list of the changes made to the proposed rules from the draft rules: ODJFS Changes

Proposed Changes to Implement Bundling

 On November 16, 2009, ODJFS issued proposed rules which include changes to the nursing facility chart of accounts and cost report necessary to implement the H.B.1 Consolidated Services provisions (bundling). The public hearing on the proposed rules is December 23, 2009 and further changes may occur before final adoption.

Cost Report Changes

• Schedule A-1 Summary of Inpatient Days:
  • Column added to report Medicaid Managed Care days separately from “Veterans and Other.” Providers will have to track these days beginning January 1, 2009.
  • Changed the heading for schedule A-1, column 9 to read "Medicare Managed Care, Veterans and Other Days."
• Schedule B-2 Direct Care Costs:
  • Adds lines for new Oxygen, and Therapy accounts.
  • Proposed rules no longer have a separate account for OTC Pharmacy as in the draft rules. OTC pharmacy will be reported in 6301 or 6311.
• Schedule C Ancillary/Support Costs:
  • Adds lines for new Resident Transportation and Custom Wheelchairs accounts.
• Schedule E-1 Return on Equity Capital of Proprietary Providers:
  • Completion of schedule is now optional.
• Attachment 1 Revenue Trial Balance:
  • Adds lines for new Resident Transportation and Custom Wheelchairs accounts.
• Attachment 5 Nurse Aide Training Statistical Information:
  • Removes Row 1 Column 1-4 for quarterly breakdown of number of aides completing continuing education.   Only “Total” for year needs to be reported.
• Attachment 6 Wage and Hours Survey:
  • Adds lines for new direct care therapy accounts.

SUMMARY OF COSTS TO RECORD IN NEW ACCOUNTS:

Excerpts from the proposed rules (reflecting changes proposed by HWCO) are provided below detailing the costs to be recorded in each new bundling account. The most significant change from the draft rules was descriptions previously identifying accounts as “Medicaid only” have been revised so payor type is not restricted. This alleviates several reporting conflicts that had been created.

• 6322 Oxygen: Beginning 8/1/09 report all oxygen other than emergency stand-by only in this account. This includes contents of oxygen cylinders or tanks, including liquid oxygen, oxygen producing machines (concentrators) for specific use by an individual recipient, and costs of equipment associated with oxygen administration, such as: carts, regulators/humidifiers, cannulas, masks, and demurrage, pursuant to rule 5101:3-3-19 of the Administrative Code.
   
• 7631 Resident Transportation: For the period 8/1/09 - 8/17/09 and for 10/1/09 and forward report all transportation expenses in this account except for expenses related to assets which meet capitalization guidelines and should be reported as capital assets in account 8050. Resident transportation costs for the period 8/18/09 - 9/30/09 are reimbursed on a direct bill basis.
   
• 7735 Custom Wheelchairs: Beginning 8/1/09, this account includes the cost of all custom wheelchairs and related repairs. Report all expenses related to wheelchairs in this account except for those wheelchairs that meet the capitalization guidelines.
• Therapy Costs which are billable either to Medicare, directly to Medicaid by NFs, or other third-party payors: Report expenses through 7/31/09 in account numbers 9600 through 9700.2. Beginning 8/1/09 use account numbers 6600 through 6680.2 under Direct Care Therapies. Therapy co-payments should be reported in the contract sub-account under the applicable therapy account.