Client Alerts

FASB Issues Proposal to Delay Effective Dates to Provide Relief for Certain Entities The Financial Accounting Standards Board (FASB) has issued a proposed Accounting Standards Update that would grant private companies and certain not-for-profit organizations additional time to implement FASB standards on leases, current expected credit losses, and hedging.  Public comment ends September 16, 2019. In [...]

Many 340B covered entities utilize entity-owned retail pharmacies to assist patients in accessing affordable medications. While there are many considerations to be considered in the operation of a retail pharmacy, one thing is very clear: If the pharmacy is owned by a 340B covered entity (CE), the pharmacy must adhere to the same 340B Program rules [...]

Low Volume Hospital Payment Adjustments for FFY 2020 The Bipartisan Budget Act of 2018 modified the qualifying criteria for the low volume hospital payment adjustment for fiscal years 2019 through 2022.  Under the modified criteria, the payment increases are applicable for hospitals that have less than 3,800 total discharges and are located more than 15 [...]

In a memorandum dated June 3, 2019, from John Upchurch, the Georgia Department of Community Health (DCH) communicated the process of the State Fiscal Year 2019 Nursing Home Upper Payment Limit (UPL) payments. The transfer amounts and gross nursing home UPL funds are available on the DCH website: https://dch.georgia.gov/nursing-home-supplemental-reimbursement. The timetable for these payments is [...]

-HRSA Audits and Your 340B Program-Lessons Learned in the Field As you are aware, your 340B Program is subject to HRSA audits. These can be random or targeted audits. As your number of contract pharmacies and child sites increase, so do your chances of being selected for an audit. Adverse findings are publicly posted on [...]

Recently, Medicare Administrative Contractors (MACs) notified certain hospitals of potentially aberrant data on their Worksheet S-10 for cost reporting periods beginning in federal fiscal year 2017 (i.e., October 1, 2016, through September 30, 2017).  The letter requests providers review their reported data, specifically Line 20, Column 2 - Charity Care Charges for Insured Patients.  It [...]

The Georgia Department of Community Health (DCH) has communicated to providers in a memorandum dated November 30, 2018 that DCH is preparing to make interim payments for the State Fiscal Year 2019 Disproportionate Share Hospital program.  Interim payments will not be provided to private hospitals due to the unavailability of state matching funds. The [...]

CMS has instructed Medicare Administrative Contractors (MACs) to audit provider cost report data reported on Worksheet S-10.  The focus of the audits is on charity and bad debt adjustments reported that are now being utilized to distribute Medicare Uncompensated Care payments.  The MACs are reviewing policies that govern which patient accounts receive these adjustments [...]

In a memorandum dated September 11, 2018, from John Upchurch, the Georgia Department of Community Health (DCH) communicated survey instructions for completing the FY 2019 Disproportionate Share Hospital (DSH) Data Survey.  These instructions can be accessed at the following link: https://dch.georgia.gov/indigent-care-trust-fund. Myers and Stauffer will send the survey to each hospital via their web [...]