Date: January 21, 2019
To: All IPPS Hospitals
From: Ellen Corwin, Director

Subject: Availability of the Proposed Federal Fiscal Year (FY) 2020 Wage Index Public Use Files (PUFs) and Deadline for Requesting Corrections to the Wage Index Data

On January 31, 2019, the Centers for Medicare & Medicaid Services (CMS) released the proposed FY 2020 wage index PUFs. This letter addresses the criteria and process for hospitals to request corrections to their wage index data. All requests from hospitals for corrections to their FY 2020 wage index data must be submitted to and received by their Medicare Administrative Contractors (MACs) on or before February 15, 2019.

Availability of Wage Index PUFs

Two PUFs are available on CMS's Web site on January 31, 2019. One PUF contains one spreadsheet of data with six tabs: first, a tab with a description of what is on the subsequent tabs, second, a tab with the Worksheet S-3, Parts II and III variable layout with an explanation of each variable from Form CMS-2552-10 that is used for the wage index, third, a tab that contains the Worksheet S-3 wage data (which includes Worksheet S-3, Parts II and III wage data from cost reporting periods beginning on or after October l, 2015 through September 30, 2016; that is, FY 2016 wage data), fourth, a tab that contains the occupational mix data (which includes data from the calendar year (CY) 2016 occupational mix survey, Form CMS-10079), and a fifth tab containing the Worksheet S-3 wage data of hospitals deleted from the third tab (that is, the hospitals on this fifth tab are considered "deleted" from the January wage data PUF), and a sixth tab containing the CY 2016 occupational mix data (if any) of the deleted hospitals listed in the fifth tab. The data in the third and fourth tabs is generally what will be used in the development of the proposed FY 2020 wage index, to be published in the Federal Register in the spring of 2019. The second PUF displays a comparison of area average hourly wages for FY 2019 (final) versus FY 2020 (preliminary).

The FY 2020 wage index PUFs will be available on the Internet on CMS's web site. To access the PUFs directly, the address is: https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/AcuteInpatientPPS/Wage-Index-Files-Items/FY2020-Wage-Index-Home-Page???????

Alternatively, the American Hospital Association generally makes the wage index files available to individual State hospital associations. Hospitals may want to check with their State hospital association to see if they have or will be getting the files. CMS will notify the American Hospital Association, the Federation of American Health Systems, and the Association of American Medical Colleges of the release of the files.

Additional Tabs for Deleted Hospitals' Worksheet S-3 and Occupational Mix Data

As noted above, CMS is including in the January PUFs a fifth tab containing the Worksheet S-3 wage data of hospitals deleted from the third tab of Worksheet S-3 wage data, and a sixth tab with the occupational mix data (if any) of the deleted hospitals listed on the fifth tab. That is, the hospitals on the fifth and sixth tabs are considered "deleted" from the January 2019 wage and/or occupational mix data PUFs. Note that it is possible for a hospital's Worksheet S-3 wage data not to be deleted and to be included on the third Worksheet S-3 wage data tab, but there may be something aberrant only about the hospital's occupational mix data, in which case that hospital's occupational mix data would appear on the sixth tab, indicating deletion only from the January 2019 occupational mix PUF. If the hospital's Worksheet S-3 wage and/or occupational mix data can be improved to the satisfaction of the MAC and CMS, the hospital's data could be restored to subsequent PUFs for the FY 2020 wage index. Hospitals' data are placed on the "deleted" tabs for different reasons. Please contact your MAC in order to document and revise your hospital's data as appropriate.

Hospital Requests for Corrections to the Wage Index Data

As noted in the wage index development timetable (previously sent, and attached for your convenience), hospitals may request: 1) corrections to errors in the January 2019 PUF due to CMS or MAC mishandling of the wage index data, and 2) corrections to MAC desk review adjustments included in the January PUF. No newly initiated wage data revisions will be accepted by the MACs at this point, as it is too late in the process for the MACs to timely handle new data. A hospital that wishes to correct its data under these criteria must submit its request along with complete appropriate detailed documentation to the MAC's office no later than February 15, 2019. Note that February 15 is the deadline for the MACs' receipt of correction requests from hospitals. Requests postmarked by February 15, but not received until after February 15, are unacceptable.

All hospitals are required to verify the accuracy of their wage data in the January PUFs. The February 15 deadline is the final opportunity for hospitals to request corrections to their wage index data before we post the final wage index files on April 30. After the April 30 PUFs are posted, changes to the wage index data will be limited to only situations involving errors by CMS or the MACs that the hospital could not have known about before CMS's release of the April 30 final PUFs.

If a hospital disagrees with the MAC's resolution of a requested change, the hospital may appeal to CMS (via letter and electronic copy, and send a copy to the MAC) in an effort to resolve policy disputes. Any such appeal must be made by April 4, 2019, in order to allow time for consideration, and must clearly identify the policy issue involved. As specified in the FY 2020 wage index development timetable (attached for your convenience), the hospital's letter must be received by CMS (and a copy received by the MAC) by this date. Also, per the wage index timeline, hospitals shall send to CMS an electronic and a hard copy of the appeal with complete documentation supporting their request (see the FY 2020 wage index timeline for complete details). CMS will not consider matters pertaining to the adequacy of supporting documentation. MACs are in the best position to evaluate matters regarding the adequacy of cost data and cost finding, and these matters should be resolved earlier in the cost reporting process (the cost reporting periods ended nearly 2 years ago).

Note: Effective with the FY 2019 wage index, CMS instituted an additional appeals process for hospitals to appeal data corrections made by CMS after posting of the January PUF. To allow input from hospitals concerning corrections made by CMS after the posting of the January PUF that do not arise from a hospital request for a wage data revision, hospitals would use the soonest approaching appeal deadline to dispute any adjustments made by CMS. However, if a hospital was notified of an adjustment within 14 days of an appeal deadline, the hospital would have until the next appeal deadline to dispute any adjustments. That is, for any adjustments made by CMS after January 31, 2019, the date the January 31, 2019 PUF is posted, and at least 14 calendar days before the April appeals deadline of April 4, 2019 (i.e., March 21, 2019), hospitals would have until April 4, 2019 to dispute those adjustments. For any adjustments made by CMS between 13 calendar days before the April appeals deadline (i.e., March 22, 2019) and 14 calendar days before the May appeals deadline (i.e., May 16, 2019), hospitals would have until the May appeals deadline (which is May 30, 2019 in the FY 2020 Wage Index Timetable) to dispute the adjustments. In cases where hospitals disagree with CMS adjustments of which they were notified 13 calendar days before the May appeals deadline (i.e., May 17, 2019) or later, the hospitals could appeal to the PRRB with no need for further review by CMS before such appeal.

As with the existing process for requesting wage data corrections, CMS stated in the FY 2018 IPPS/LTCH PPS final rule that a hospital disputing an adjustment made by CMS after the posting of the January PUF would be required to request a correction by the first applicable deadline. For example, if a hospital was notified on March 20, 2019 of an adjustment to its data by CMS and did not appeal by April 4, 2019, the hospital would not be able to appeal by May 30, 2019 or bring the case before the PRRB. That is, hospitals that do not meet the procedural deadlines set forth earlier would not be afforded a later opportunity to submit wage index data corrections or to dispute CMS' decision at the PRRB with respect to requested changes.

If you have any questions, please contact Lewis Martin at 651-994-3914 or lewis.martin@noridian.com.

ATTACHMENT: FY 2020 Wage Index Development Timetable

CMS'S EMAIL and MAILING ADDRESS FOR WAGE INDEX DISPUTE RESOLUTION:

wageindexreview@cms.hhs.gov

Centers for Medicare & Medicaid Services
c/o Wage Index Team, CMM/HAPG/DAC
Room C4-08-06
7500 Security Boulevard
Baltimore, Maryland 21244-1850