Date: April 30, 2018

To: All IPPS Hospitals

From: Ellen Corwin, Director

Subject: Availability of the Final Federal Fiscal Year (FY) 2019 Wage Index Data Public Use Files and Deadline for Requesting Corrections to the Data
The Centers for Medicare & Medicaid Services (CMS) released the final FY 2019 wage index data public use files (PUFs) on APRIL 27, 2018. The files are available for the limited purpose of identifying any potential data entry or transmission errors made by CMS or the A/B Medicare Administrative Contractors (MACs), NOT for the initiation of new revision requests. The files include: 1) a tab containing the Worksheet S-3 wage data from cost reports beginning during FY 2015 (that is, on or after October 1, 2014 and before October 1, 2015), and 2) a tab containing the CY 2016 occupational mix survey data. Also, we have added additional tabs containing the Worksheet S-3 wage data of hospitals deleted from master wage data file, and a tab containing the CY 2016 occupational mix data (if any) of hospitals deleted from the master occupational mix data file. Data that were incorrect in the February 2, 2018 wage data PUFs, but for which no revision request was received by the February 16, 2018 deadline, will not be considered for correction at this stage. Hospitals should promptly review their final wage index data files and compare that to the data in the April 27, 2018 PUF to ensure that both their Worksheet S-3 wage and occupational mix data are accurate. All requests from hospitals for corrections to their FY 2019 wage index data files must be submitted to and received (i.e., not postmarked) by both their A/B MACs and CMS on or before May 30, 2018.

Hospitals are reminded that the average hourly wages and wage index values published in the proposed rule are based on data transmitted to CMS by early February. Therefore, the data in the proposed rule does not reflect the wage data to be used to calculate the final FY 2019 wage index. In addition, be aware that appeals filed in April 2018 are still pending, and may not be reflected in the APRIL 27, 2018 PUF. In order to ensure the hospital's wage data are accurately reflected in CMS' files prior to the calculation of the final FY 2019 wage index, hospitals must carefully review the final wage index data PUFs posted on APRIL 27, 2018.

Availability of the Final Wage Index PUFs
The two final FY 2019 wage index data PUFs were posted on the Internet on APRIL 27, 2018. The data will be used in the development of the final FY 2019 wage index, which will be published in the Federal Register by August 1, 2018. The final FY 2019 wage index data files are available at CMS' Web site: https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/AcuteInpatientPPS/Wage-Index-Files-Items/FY-2019-Wage-Index-Home-Page.

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

We strongly encourage all hospitals to access the final FY 2019 wage index files and verify the accuracy of their data. The May 30, 2018 deadline will be hospitals' last opportunity to request corrections to their data files for the FY 2019 wage index.

Requesting Corrections to the Wage Index Data
As noted in the wage index development timetable (previously sent, and attached for your convenience), hospitals have the right to request corrections to their wage index data files if they can establish that the A/B MACS or CMS made a data entry or transmission error in the final FY 2019 wage index data files. A hospital requesting a correction must submit its request, by hard copy and email, along with complete, appropriate detailed documentation, to both its A/B MACS and CMS, no later than May 30, 2018. Per the attached wage index development timetable, send appeals to both:

Email: wageindexreview@cms.hhs.gov

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

Refer to the attached wage index development timetable for complete information regarding submission of correction requests. Note that May 30, 2018 is the deadline for the MACs' and CMS' receipt of correction requests and supporting documentation from hospitals. Requests postmarked by May 30, 2018, but not received until after May 30, 2018, are unacceptable. Requests received via email after May 30, 2018 are unacceptable.

Neither the A/B MACs nor CMS will consider the following types of requests in conjunction with this process:

• Requests for corrections to wage data and/or occupational mix data that were submitted too late to be included in the data transmitted by the MACs to CMS on or before April 5, 2018;
   
• Requests for correction of errors that were not, but could have been, identified during the hospital's review of the preliminary wage index data files released in February 2018; or,
   
• Requests to revisit factual determinations or policy interpretations made by the MAC or CMS during the wage index data correction process prior to the April 27, 2018 release of the final FY 2019 wage index files.

Data that were incorrect in the February 2, 2018 wage index public use files, but for which no revision request from the hospital was received by the A/B MACs as of the February 16, 2018 deadline will not be changed at this stage for inclusion in the wage index. Please note that, while MACs may make other revisions to hospitals' wage data at this time as part of the ongoing cost report settlement process, these changes will not be incorporated into the data to be used for the wage index.

Note that May 30, 2018 is also the deadline for hospitals to dispute data corrections made by CMS of which the hospital is notified on or after 13 calendar days prior to April 5, 2018 (i.e., March 23, 2018), and at least 14 calendar days prior to May 30, 2018 (i.e., May 16, 2018), that do not arise from a hospital's request for revisions. (Data corrections made by CMS of which a hospital is notified on or after 13 calendar days prior to May 30, 2018 (i.e., May 17, 2018) may be appealed to the Provider Reimbursement Review Board (PRRB)). CMS and the MACs must receive requests with complete documentation by this date via mail and email to the addresses above.

The A/B MACs and CMS will review each request upon receipt and will determine whether or not the request meets the criteria for correction of the final wage index files. If a correction is necessary, the wage data will be revised accordingly and will be included in the final FY 2019 wage index, effective October 1, 2018. CMS will send each hospital a letter explaining CMS' decision regarding the hospital's correction request.

If you have any questions, please contact Barb Miers at 651-994-3907 or Barbara.miers@noridian.com.

ATTACHMENT:
FY 2019 Wage Index Development Timetable