Your top questions about CMS Worksheet S-10 filing requirements

Navigating changes to CMS uncompensated care reporting requirements is tricky—but accurate filing of Worksheet S-10 is essential. This FAQ will help.

Appropriate completion and filing of Worksheet S-10 as part of your hospital’s Medicare cost report are essential to ensure compliance. The Centers for Medicare & Medicaid Services frequently updates its uncompensated care reporting requirements, making navigation of these changes tricky to say the least.

For example, CMS introduced a notable set of revisions in late 2022 with its Transmittal 18. The revisions, which included new and modified cost reporting instructions and templates, are effective now and have created additional confusion around completing the already-complicated Worksheet S-10.

We know you have questions about Worksheet S-10 filing requirements. The following are answers to some of the most common questions we receive from your peers around the country. In addition, we’ll share information about how Kodiak’s specialists—and the power of Kodiak RCA data—can help increase the efficiency of your uncompensated care cost reporting.

Q: Do we need to prepare an Exhibit 3B and 3C for our hospital, rehabilitation, and psychiatric unit?

A: Exhibits 3B and 3C of Worksheet S-10 are designed to capture charity care charges and total bad debt, respectively. Rather than creating a separate exhibit for each individual provider type with a CMS Certification Number, we would recommend adding a column to Exhibits 3B and 3C that lists each CCN. This helps avoid the extra work of completing separate exhibits for each CCN.

Q: If we don’t have a subacute unit, do we need to prepare Part 1 and Part 2 of Worksheet S-10?

A: Yes. Part 1 of Worksheet S-10 covers uncompensated care for the entire hospital complex. Part 2 covers uncompensated care data for the hospital only. If you attempt to submit Part 1 without Part 2, you will get an error message. Therefore, all hospitals must prepare and submit Parts 1 and 2.

Q: Should the deductible and copay reported on Column 11 and the amounts reported on Line 20, Column 2, be the same?

A: Column 11 is where you enter the amount of deductible, coinsurance, and copayment the patient owes according to their medical insurance coverage, if applicable. Line 20, Column 2, is where any unpaid patient portions of a patient’s deductible, coinsurance, and copayment should be reported as long as financial assistance was awarded per the policy. It’s important to note that any amount on Line 20, Column 2, should not be greater than what’s reported in Column 11.

For example, if a patient’s deductible and copay was $1,600, and the patient made a payment of only $100, the unpaid portion of the deductible, coinsurance, and copayment for that patient for that reporting period would be $1,500. Therefore, $1,600 would be reported on Column 11, and $1,500 would be reported on Line 20, Column 2.

Q: When looking to make updates to our organization’s financial assistance policy, what key items should we make sure to include?

A: It’s a good idea to review your FAP regularly to make sure that your organization has verbiage about any applicable uninsured and self-pay discounts your organization provides. Also, if your hospital allows for Medicaid noncovered services, Medicaid exhausted length of stay, or other indigent care services, verbiage regarding that also should be included in the FAP, according to the requirements outlined in Transmittal 18.

In addition, another key FAP takeaway from Transmittal 18 is making sure hospitals include verbiage surrounding medical necessity to ensure all applicable discounts your organization provides are covered and can be included in your S-10 reporting.

Q: Will Medicare Administrative Contractors audit both Parts 1 and 2 of Exhibit 3B and 3C going forward?

A: Currently, the MACs have communicated to hospitals that Part 1 of Exhibits 3B and 3C will be audited next year. Similar to how it was handled in the past, CMS is gathering the information for Part 2, which is the hospital portion only, and hospitals are awaiting further instruction from the agency on how it will use the data.

Q: As a Kodiak RCA customer, can we leverage the data already stored in RCA to complete the Worksheet S-10 filings?

A: No. There is not a user end report for RCA users to download and submit—this is an additional service that Kodiak’s team can perform for RCA customers. Because Worksheet S-10 and its corresponding Exhibits 3B and 3C require substantial amounts of data, Kodiak uses our expertise to obtain the large amount of data needed from RCA, aggregate it, and then accurately and efficiently analyze the transactions reported on Exhibit 3B and 3C used for Worksheet S-10.

Need more help with Worksheet S-10?

Staying compliant with CMS uncompensated care reporting requirements is an important part of your organization’s overall financial health. Kodiak’s specialists are available to answer more of your uncompensated care reporting questions, help you better understand reporting updates, and implement more efficient processes that can close compliance gaps.