2022 Institutional Cost Report (ICR)

NYS Department of Health
Division of Finance & Rate Setting
Bureau of Hospital & Clinic Rate Setting

  • Presentation is also available in Portable Document Format (PDF)
April 12, 2023

Agenda


Software, Support & Filing Procedures

  • ➣ Obtaining Software and Support
    • The Institutional Cost Report (ICR) Software will be available for download from the Health Financial Systems (HFS) website.
      • The Department will provide hospitals with the URL, Username and Password using the Health Commerce System (HCS) - Hosp Institutional Cost Rpt application.
    • ICR problem resolution and questions:
      • Send email to: Hospital.ICR@health.ny.gov
      • Include in subject line: "2022 ICR - hospital name"
      • For problem resolution, send your "four-pack" files (CR, IC, B_, T_) to this address (ED_ file may also be sent). The files will then be forwarded to HFS, if necessary.
        Note: The Department prefers that hospitals do not email these files via secure email (only necessary when HIPAA or PHI data are included)
    • ➣ Electronic Filing Procedures
      • DH file: Electronic submission through Health Commerce System (HCS) - Hosp Institutional Cost Rpt application):
        • Due date: Friday, June 16, 2023
      • Supporting documents due within 5 business days of ICR submission to be considered a valid cost report submission:
        • Signed CFO/CEO certification (verify DCN matches the submitted ICR)
        • Edit Report (Initialed with explanations)
        • Final Audited Financial Statements
          • ✤ "Draft" statements cannot be used for audit purposes
        • Audit Fee Form (NEW for 2022 ICR submissions)
        Note: the Edit Report no longer needs to be submitted separately since it is embedded within the ICR DH file
      • Email files to: AFS@health.ny.gov
      • Signed CFO/CEO Certification:
        • File named with 7-digit operating certificate number and "_CFO"
          • Example: 1234567_CFO
      • Audited Financial Statements:
        • File named with 7-digit operating certificate number and "_AFS"
          • Example: 1234567_AFS
      • Audit Fee Form (NEW):
        • File named with 7-digit operating certificate number and "_AFF"
          • Example: 1234567_AFF
        Note: The Department prefers that hospitals do not email these files via secure email (only necessary when HIPAA or PHI data are included)
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2022 ICR Audit Fees

  • Due within 5 business days of filing ICR
  • Same banking information as previous years
  • Same fee schedule as previous years
  • Email notification to be released for facility-specific audit fees
  • Additional fees may be assessed when # of submissions exceeds 2
  • New form with payment information needs to be emailed
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Health Commerce System (HCS)

  • Website
  • Communication Tool
    • Secure network for posting provider information
    • Important to keep email address current to receive notifications
      • Facility's responsibility
      • Email list is separate from the DOH public website electronic mailing lists
  • HCS Help Contact
    • Commerce Accounts Management Unit Help Desk: 1-866-529-1890 or camu@its.ny.gov
      • HCS accounts
      • Password resets
      • Removal of employee
  • HCS Access Contact
    • Hospital Fee-for-Service Rate Unit: HospFFSunit@health.ny.gov
      • Receiving access to the ICR (or other hospital applications)
      • Rate related questions
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Department of Health Public Website

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2022 ICR Updates

  • Exhibits (changes, additions & clarifications)
    • Cost Centers
      • Opioid Treatment Program
        • ✤ Per CMS T18 - Effective on or after January 1, 2022, CMS line 102
        • ✤ Previously CMS line 90.40
        • ✤ Will maintain ICR Cost Center 262
    • Exhibit 3 (S-3 Part I) - Complex Statistical Data
      • Temporary Expansion COVID-19 PHE Acute Care
        • ✤ Addition of CMS Line #34, ICR Line #618
        • ✤ Refer to Medicare instructions - Section 4005.1
    • Exhibit 26A (G-3) - Statement of Revenue & Expenses
      • COVID-19 Revenue - Not included in CMS line 24.50
        • ✤ Addition of CMS Line #24.51 - 24.60, ICR lines 131 - 140
        • ✤ Specify the type/source of funding
    • Health Care Worker Bonus (HWB)
      • Exhibit 27 - Appropriations from Special Funds
        • ✤ New lines 212-214, report both inpatient & outpatient
    • Health Care Worker Bonus (HWB)
      • Exhibit 12 - (A-6) Reclassifications
        • ✤ Reclassify bonus and FICA to Cost Center 003 - Employee Benefits
      • Exhibit 14 - (A-8) Adjustments to Expenses
        • ✤ All-payor adjustment (Negative) from Cost Center 003- Employee Benefits
        • ✤ Bonus paid and NYS reimbursement of employer FICA
        • ✤ Use CMS line #34.78, ICR line # 344, - HWB or HWB/FICA
        • ✤ Use CMS line #34.79, ICR line # 345, - FICA
      • Exhibit 12 - Reclass Example
        Columns Entry
        Explanation HWB/FICA
        Entered the increased amount  
        Cost Ctr - 00700/001 Cost Center 003
        Salaries - 00701/001 Total of all HWB and FICA(if combined) to be reclassed from Dept.
        Fringe Benefits -00704/001 Total FICA (if recorded separate) to be reclassed from Dept.
        Entered the decreased amounts  
        Cost Ctr - 00700/xxx Cost center xxx where HWB and its FICA is recorded
        Salaries - 00701/xxx (Negative of) HWB and its FICA, if combined,
        Fringe Benefits - 00704/xxx (Negative of) FICA, if recorded separate
      Exhibit 12 - Reclassifications
      • Health Care Worker Bonus (HWB)
        • Exhibit 14 - Adjustment example
          Columns Entry
          Description HWB or HWB/FICA
          All Payors - 00708/344 (CMS 34.78) Cost center 003
          Amount - 00707/344 Amount of HWB (negative amount)
          Salary - 00710/344 Amount of HWB (negative amount)
          Description HWB( FICA Only), if needed
          All Payors - 00708/345 (CMS 34.79) Cost center 003
          Amount - 00707/345 Amount of FICA (negative amount)
          Non-Salary - 00710/345 Amount defaults to Non-Salary
        • Exhibit 14 - Adjustment to Expenses
        • Exhibit 41 - Funded Depreciation Schedule
          • Home Office Amounts Assigned or Allocated to Hospital
            • ✤ Column for hospital-only costs that reconciles to AFS
            • ✤ Column for Home Office assigned or allocated values
              • Inclusion of Home Office amounts (Form 287)
        • Exhibit 46 - Hospital Service Revenue
          • Clinic Line 002
            • ✤ "Article 28 General Clinic, MSC 235, Visit Fees - Outpatient"
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      ➣ Edits

      • Importance
        • Improves Data Integrity
          • ✤ Budgetary Analysis
          • ✤ DSH Model
        • Explains data anomalies
          • ✤ Low Utilization
          • ✤ Positive values entered as negatives & vice versa
          • ✤ Charge Structure
        • Reduce ICR Audit findings and/or questions
          • ✤ Prevents errors to avoid audit findings
          • ✤ Edit explanations provided to Auditors
        • Types of Edits
          • Fatal (3xxxx)
            • ✤ Identify the cause and make appropriate correction(s)
            • ✤ Notify ICR mailbox when edit is believed non-applicable and cannot be cleared
          • Non-Fatal (4xxxx)
            • ✤ Intent is to identify unexpected data or combinations
            • ✤ Only change data if an entry is incorrect or omitted
            • ✤ Do not make changes to unsupported values to clear Edit(s)
              • Edits comparing Exhibit 3 (S-3, Part I) versus Exhibits 32, 33, & 34 (Utilization)
              • PS&R versus Patient Financial System
          • ✤ All non-fatal edits require an explanation
      • Edit Responses
        • Explanation should provide insight
          • ✤ Should not be left blank
          • ✤ Should not state “confirmed”, except for edits requesting confirmation (ex - edit 41806)
          • Should not state deferment until audit
        • New / Updated Edits
          • Exhibit 52 - Medicaid Service Code (MSC) Assignment
            • ✤ Each long-term care MSC limited to one cost center
          • Tighter criteria on edits based review of 2020 & 2021 ICRs and hospital comments

      Note: Any Edits that are to be cleared should be done BEFORE filing either the Medicare or Medicaid cost report

      • Employee Discount Days vs. Courtesy Days
        • Employee Discount Days on Exhibit 3 (S-3, Part I)
          • IRF reported separately
        • Courtesy Days reported on Exhibit 32 (Utilization)
          • Employee Discount Days
          • Other - Example: Related Physicians, Clergy, etc.
      • Primary Payor
        • After posting the Explanation of Benefit (EOB), self-responsible amounts are still the primary payor
          • Not the secondary payor, if different from primary
          • Not self-pay or uninsured
        • Charity Care Primary Payor
          • Only if entire account does not have third-party coverage and was or is to be written off
          • HFAL when other primary payor to Lines 382, 383, 386 and 391
      • Payor changes for later eligibility qualification
      • Offsets
        • Typically would reduce revenue or expense to zero
          • Unless limited, like interest restricted in use by donor of principal
        • Should not result in negative expense
        • Reminders
          • When including ending accrual, consider beginning accrual
          • Use hard-coded lines on Exhibit 18, when available
            • ✤ Parking, 068 and 069
            • ✤ Malpractice, 025
        • ICR Submissions
          • Non-Compliance
            • CEO/CFO certification, audited financials or audit fees not received
            • Edit Report
              • ✤ At least one explanation blank
              • ✤ At least one explanation shows intent to address later
              • ✤ Explanation(s) do not provide insight
          • Improper reporting
            • ✤ Voluntary Hospitals
              • Type of control not reported correctly
              • Exhibit 25 (Statement of Cash Flows) - not completed
              • Exhibit 42 (Unfunded Depreciation Waiver Override) - only with DOH approval
          • May result in rejection & required resubmission of ICR (counts toward 1st audit fee)
      • Reminders
        • 2022 ICR Submissions
          • Please review past audit findings and/or adjustments to avoid similar reporting errors
          • Backup documentation for various exhibits should be kept on-hand for audit purposes
          • All remaining non-fatal edits must include adequate explanations and initials
          • DCN's all agree - ICR submission and CFO certification
          • Recommended - submit financial statements and CFO certifications same day as ICR submission
          • Initial ICR submission should always include the most accurate data
            • ✤ Unaudited data may be used by the Department at any time
            • ✤ Ready to be audited (do not plan to fix exhibits during audit)
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      Questions?

      ICR Questions: Hospital.ICR@health.ny.gov

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