Medicare Compliance & Reimbursement

If you've had your disproportionate share hospital payment calculations challenged for including physician practice plan costs incurred by a related organization, you're not alone. Such costs were among the problems cited in a half-dozen recent DSH reviews released over the last few weeks by the HHS Office of Inspector General. Besides problems with physician practice plan costs, the OIG's findings reveal the following trouble spots in DSH accounting: inappropriately including dual eligible beneficiaries in tallies of Medicaid-eligible days; duplicating entries in computations of dual eligible days; including costs for insured patients in their uncompensated care cost figures; including costs from earlier accounting periods in UCC calculations; and improperly claiming costs for care provided to inmates of correctional facilities. The watchdog agency also identified problems at the state level, such as failing to timely adjust cost estimates to actual costs tallied in completed cost reports. The identification numbers for the reports are A-03-01-00221, A-03-01-00222, A-03-01-00226, A-04-01-00003, A-04-02-02021 and A-07-02-02097. They are available on the Web at http://oig.hhs.gov/oas/oas/cms.html. Lesson Learned: While DSH payments are a vital financial lifeline for many facilities, lingering OIG scrutiny suggests that compliance officers should make sure their organizations' accounting practices are up to snuff.