The Centers for Medicare and Medicaid Services (CMS) published the Supplemental Security Income (SSI) percentages for fiscal year (FY) 2022.
Important information on benefits and considerations for hospitals, as well as other key points for health care entities, follows below.
Key Information
Applicable Health Care Entities
CMS published SSI data for the following health care entities:
- Inpatient Prospective Payment System (IPPS) hospitals
- Inpatient rehabilitation facilities (IRF)
- Long-term care hospitals (LTCH) that bill Medicare Administrative Contractors (MAC) for Medicare beneficiary services
Resources
The FY 2022 SSI percentages can be accessed electronically on the CMS website, and the following pages focus on each applicable health care entity:
Timing
CMS issued Change Request 13569 (CR), providing technical direction to MACs on March 28, 2024.
The CR states that Medicare Part A “contractors shall update their IPPS, IRF, and LTCH provider specific files prospectively, within 30 days of the implementation date of this CR, using the latest year’s SSI ratio posted to the CMS website as of the implementation date of this CR, except when explicitly directed otherwise by CMS.”
The guidance takes effect April 29, 2024.
Data
The SSI data files contain:
- Provider number
- Provider name
- Total SSI days
- Total days
- Total SSI ratio—the ratio of days for patients entitled to Medicare Part A attributable to SSI recipients
Methodology for Calculating FY 2022 SSI Ratios
After the decision in Empire Health Foundation v. Azar, the methodology for calculating FY 2022 SSI ratios uses total Medicare days, consistent with prior CMS regulation.
Considerations for Hospitals
Hospitals should keep a few factors in mind based on their classification.
IPPS Hospitals
FY 2022 SSI ratios will generally apply to Medicare cost reports beginning on or after October 1, 2021, and prior to October 1, 2022, for settlement purposes.
For IPPS hospitals, this updated data will be used to determine their Medicare Disproportionate Share (DSH) adjustment.
IRFs
IRFs will incorporate the updated percentages into their low-income patient (LIP) adjustment.
LTCHs
LTCH discharges paid under the short-stay outlier payment adjustment will use updated SSI data.
Benefit of an SSI Percentage Recalculation for IPPS Hospitals
Current CMS regulations allow a hospital to request a recalculation of its Medicare fraction or SSI ratio based on the hospital’s cost-reporting period if it’s different from the federal fiscal year—October 1 through September 30.
Hospitals should research annually whether their facility could benefit from an SSI percentage recalculation, also known as an SSI realignment or redetermination.
If this hasn’t been historically or consistently reviewed, it’s recommended that hospitals perform a look back through all years of their SSI data. SSI recalculations can provide additional opportunities to help increase your Medicare DSH reimbursement.
Properly analyzing your SSI data, however, can be a complex process. If appropriate patient level SSI data isn’t fully obtained and analyzed properly, a recalculation could decrease your Medicare DSH reimbursement.
Learn more about how to determine the benefit of an SSI percentage recalculation and what data and analysis is required, or request a complimentary analysis to determine if your organization could benefit.
We’re Here to Help
If you have questions about potential implications of the FY 2022 SSI ratios for your hospital or would like assistance evaluating whether your hospital would benefit from a recalculation, contact your Moss Adams professional.
You can also learn more about our Provider Reimbursement Enterprise Services and find related information.