Alert

CMS Grants Extensions for Hospitals Submitting 2019 Occupational Mix Data

This article was updated August 4, 2020.

Due to the COVID-19 pandemic, the Centers for Medicare & Medicaid Services (CMS) has granted an additional extension for hospitals to submit their 2019 occupational mix survey by September 3, 2020, which was first extended to August 3, 2020. Hospitals may then submit revisions to their surveys—if needed—no later than September 10, 2020.

The 2019 survey, which was originally due for submission by July 1, 2020, applies to all pay periods ending between January 1, 2019, and December 31, 2019, and will be applied to the fiscal year 2022 wage index data.

Below is an overview of submission requirements, key considerations for hospitals, and next steps for submitting 2019 mix surveys by the extended due date.

Background

Short-term, acute-care hospitals participating in Medicare are required to collect and submit data on their occupational mix of employees to the MAC every three years.

CMS is required to collect occupational mix data every three years, according to Section 304(c) of Public Law 106-554 amended section 1886(d)(3)(E) of the Social Security Act. The law also requires the application of the occupational mix adjustment to each hospital’s wage index data.

Who's Affected

The survey applies to any hospital subject to the Inpatient Prospective Payment System (IPPS). Survey results will be applied to each hospital’s annual wage index information covering a three-year period.

Entities that aren’t required to complete the survey include:

  • Critical access hospitals
  • No- or low-Medicare utilization providers
  • Hospitals that terminate participation in the Medicare program before January 1, 2019

What's Involved

CMS requires hospitals to summarize and submit employee payroll salary and paid-hours information to their MAC. The payroll information must be identified by non-nursing personnel as well as nursing personnel, which includes registered nurses, licensed practical nurses, surgical techs, nursing aides, orderlies, attendants, and medical assistants, among others.

CMS also requires that entities report a proportionate share of home office and related organization payroll data; however, they don’t need to report employees working in areas excluded from inpatient prospective payment systems.

Additionally, contracted professional fee and hours information pertaining to outsourced services must also be reported by nursing and non-nursing categories.

Additional Considerations

The estimated time to collect and complete these surveys is approximately 480 hours, or 12 weeks, so it’s important to start the process early.

Failing to meet the deadline or reporting inaccurate information could cost an organization hundreds-of-thousands to millions of dollars in lost Medicare inpatient and outpatient reimbursement over a three-year period.

We're Here to Help

If you’d like more detail about wage index and occupational mix improvement, or if you’d like to learn more about changes to the survey and how your short-term, acute-care hospital can prepare, contact your Moss Adams professional.

Note on COVID-19

During this unparalleled time, we’re closely monitoring the COVID-19 situation as it evolves so we can provide up-to-date guidance and support to help you combat uncertainty. For regulatory updates, strategies to help cope with subsequent risk, and possible steps to bolster your workforce and organization, please see the following resources: