Presentation Transcript

1. Washington Wage Index Improvement Strategy Services

   2013 WSHA Project Report January 28, 2014
2. Meeting Roadmap Goal of the 2013 WIISS Scope of Work What has HFS been doing with WA hospitals the last 6 months? Results of This Year’s Work What does our work together mean for Washington? Key Findings Next Steps and Timeline What can WA hospitals expect from HFS in the next few months? Future Needs What’s coming up in 2014? HFS Consultants | www.hfsconsultants.com
3. 2013 Project Goals Increase Wage Index Reporting Compliance Normalizing average hourly wage data Improving Accuracy of Average Hourly Wage Data Frequently findings mean positive adjustments to the average hourly wage Knowledge Transfer Transparency of average hourly wage findings Best practices for future average hourly wage data reporting HFS Consultants | www.hfsconsultants.com
4. Scope of Work – 9 Months of Collaboration Discovery Collection of the necessary wage and financial data from hospital staff Analysis HFS’s specialized analysis and “dig deeper” approach of the wage index data identifies items that do not meet CMS guidance and areas of opportunity to enhance average hourly wage reporting Revision HFS proposes revised wage index data, and with hospital approval, submits proposed revisions to MAC corresponding with its deadline MAC Audits HFS Consultants | www.hfsconsultants.com
5. HFS Worked in Multiple Geographic Areas 2013 Wage Index Improvement Strategy Services Seattle-Bellevue-Everett CBSA Tacoma CBSA Spokane CBSA Rural Washington CBSA 44 hospitals in Washington either participated or are impacted by the work HFS Consultants | www.hfsconsultants.com
6. Who Participated in Seattle-Bellevue-Everett? Providence Health & Services University of Washington Virginia Mason Medical Center Overlake Hospital Medical Center Central Washington Hospital Evergreen Hospital Medical Center Skagit Valley Hospital Auburn Medical Center Island Hospital Cascade Valley Hospital These participants represent 93% of the CBSA wages HFS Consultants | www.hfsconsultants.com
7. Who Participated in Tacoma? MultiCare Health System Tacoma General Allenmore Hospital Good Samaritan Hospital MultiCare represent 55% of the CBSA wages Franciscan Health System – St. Joseph Medical Center HFS Consultants | www.hfsconsultants.com
8. Who Participated in Spokane? Providence Health & Services Providence Sacred Heart Medical Center Providence Holy Family Hospital These two hospitals represent 71% of the CBSA wages HFS Consultants | www.hfsconsultants.com
9. Who Participated in Rural Washington? PeaceHealth St. Joseph Medical Center Gray’s Harbor Community Hospital Providence St. Mary Medical Center Providence Centralia Hospital Samaritan Hospital Walla Walla General Hospital Wenatchee Valley Medical Center Olympic Medical Center These members represent 100% of the CBSA wages HFS Consultants | www.hfsconsultants.com
10. Net Findings and Projected Impact HFS Consultants | www.hfsconsultants.com
11. Key Findings HFS Consultants | www.hfsconsultants.com
12. Summary of Findings HFS Consultants | www.hfsconsultants.com
13. Hours Related to Paid Salaries The following hours should be removed from the payroll file for accurate wage index reporting: Hours associated with accrued, not paid, salaries Bonus hours On-Call hours Shift Differential hours PTO paid out at employee termination Buy/Sell back PTO Paid hours associated with capitalized labor costs Missed meal and missed break pay HFS Consultants | www.hfsconsultants.com
14. Hours Related to Paid Salaries The following hours should be removed from the payroll file for accurate wage index reporting (cont’d): Unpaid Family Medical Leave Unpaid Disability Unpaid Leave of Absence Baylor Plan Example: Employees work 36 hours, but get paid for 40 hours – remove 4 hour difference Seasonal Plan Example: Employees work certain months of the year, but get paid for 52 weeks – remove the time not actually employed HFS Consultants | www.hfsconsultants.com
15. Hours Related to Paid Salaries Severance Hours General Rule: If severance is booked a "salary" expense then include hours; if severance is booked as a non-salary expense than do not include hours Disability Hours General Rule: If disability hours are reduced on the payroll report they need to gross up to 100% Holiday Pay for Nurses Example: May be paid regular pay + holiday pay + overtime; ensure that hours are not being double- counted HFS Consultants | www.hfsconsultants.com
16. Contract Labor Patient Care Remove wages and hours from excluded and non-allowable cost centers Remove non-patient care wages and hours related to: Non-professional fees (i.e. travel, miscellaneous overhead) Non-patient care and overhead services (i.e. transcription) Report additional amounts related to: Dialysis Perfusion Other temporary patient care staff not reported as “Registry” Patient care staff reported from the home office HFS Consultants | www.hfsconsultants.com
17. Contract Labor Overhead Contract Labor Report additional Administrative & General (A&G, e.g. legal and consulting services), dietary, and housekeeping contract labor identified from a thorough review of trial balance and accounts payable detail Report additional A&G contract labor from the corporate and regional home office Remove non-allowable overhead amounts (i.e. security). HFS Consultants | www.hfsconsultants.com
18. Wage Related Costs Defined Benefit Pension Plans For wage index purposes, allowable pension costs will be calculated as the average cash contributions paid over a 3-year period The 3-year period used is the current cost report period and the periods immediately preceding and following it CMS states that the 3-year average is allowable even if it exceeds the current period contribution There is no requirement to demonstrate that the amount satisfies a liability under ERISA or any other actuarial basis HFS Consultants | www.hfsconsultants.com
19. Wage Related Costs For Defined Benefit Pension Plans, hospitals will need to: Obtain contribution data from the pension trustee, insurance carrier, Schedule B or SB of IRS Form 5500 and, if applicable, from accounting records documenting allocations among providers Retain and make available support for the 3-year average, the prefunding balance and the prefunding installment, where applicable High scrutiny from MAC auditors HFS Consultants | www.hfsconsultants.com
20. 2013 WIISS Next Steps HFS monitors and supports the wage index revisions through MAC audit and Final Rule January – August 2014 Review February 2014 PUF to ensure revisions are accepted and properly reflected in HCRIS data HFS will provide a final report in March with final impact estimates HFS Consultants | www.hfsconsultants.com
21. Future Wage Reporting Issues HFS Consultants | www.hfsconsultants.com
22. What does HFS see in Your Future? 2014 Occupational Mix Survey (OMS) CMS estimates it takes about 400 hours to complete Similar to wage index reporting, the OMS is deceptively complex and difficult to report accurately OMS has a material impact on wage index and Medicare reimbursement OMS can reduce the AHW of a hospital and CBSA significantly reducing Medicare reimbursement Due by July 1, 2014 Short turn around and infrequency of the survey can make it difficult to complete the survey accurately HFS Consultants | www.hfsconsultants.com
23. Purpose of the Occupational Mix Adjustment Control the effect of hospitals’ employment choices on the wage index Hospitals may choose to employ different combinations of nursing personnel The varying labor costs associated with these choices reflect hospital management decisions rather than geographic differences in the costs of labor Using the CMS methodology, we can measure the impact of the most recent OMS (CY10) on hospitals in Washington HFS Consultants | www.hfsconsultants.com
24. How does Occupational Mix work? HFS Consultants | www.hfsconsultants.com
25. How does Occupational Mix work? HFS Consultants | www.hfsconsultants.com
26. Impact of the OMS on Washington OMS Impact – Calendar Year 2010 10 out of 11 CBSAs in WA were negatively impacted HFS Consultants | www.hfsconsultants.com
27. Tips for Preparing the OMS HFS Consultants | www.hfsconsultants.com
28. Knowledge Sharing Knowledge Sharing and Future Wage Index Support Carry findings forward into FFY 2016 FYE 2012/2013 cost reports likely contain the same wage index corrections that were revised during this year’s work HFS Consultants | www.hfsconsultants.com
29. Knowledge Sharing Knowledge Sharing and Future Wage Index Support Further study to correct compliance findings from this year’s work HFS recommends targeted studies in Washington to address specific recommendations found during the 2013 work HFS Consultants | www.hfsconsultants.com
30. Thank You – WSHA and HFS Contacts HFS Consultants | www.hfsconsultants.com
31. Questions / Discussion HFS Consultants | www.hfsconsultants.com