Institutional Cost Report (NYSICR)
Frequently Asked Questions
(for 2023 ICR)
- Q & As also available in Portable Document Format (PDF)
| Question | Answer | |
|---|---|---|
| A. Reporting Questions | ||
| 1 | Does line 24.50 include Paycheck Protection Program (PPP) amounts received (Exhibit 26A)? | The published instructions state "Enter the aggregate revenue received for COVID 19 PHE funding including both provider relief fund (PRF) and Small Business Administration Loan Forgiveness amounts." |
| 2 | Where should the hospital report COVID-19 revenue? | Any COVID funding, including private donations, should be reported within Line 24.50 if it meets the CMS description for the Line. COVID funding that is not reported in Line 24.50 should be included on variable lines 131-140 in Exhibit 26A. |
| 3 | What is the treatment of interest earned on PRF [CARES Act Provider Relief Fund] amounts? | The US Department of Health and Human Services (HHS) stipulates that providers earning interest on PRF funds may either return the interest or may use the interest earned in a manner that would be compliant with the purposes of the PRF principal. For those that returned interest, the amount reported in the ICR as PRF funding would not include the returned interest or would be net of interest yet to be returned. Where PRF reporting allows the provider to retain the interest as used for the principal purpose, no interest offset would be made because this amount is to be treated as interest earned under a restricted grant. |
| 4 | What are the primary payor categories? | Definitions relating to primary payor categories for reporting of Exhibits 32, 33, 34 and 46 may be found within the ICR instructions. Further clarification on specific primary payors as it relates to Exhibit 46 HFAL reductions are provided below:
Insured means at least one provided service is covered by at least one of the patient's third-party payors. It is not necessary to collect from the third-party. HFAL reductions for these accounts are reported in the primary payor's charity line. (For 2021 ICR, Essential Plans are included as insured.) Uninsured means the hospital expects a patient with NO third-party coverage for ANY service provided in the account to pay at least a portion of the charges. This includes patients electing to self-pay instead of billing third parties. Free, Charity is for patients for whom application of the hospital financial aid policy (HFAL) results in reduction (write-off) of charges to zero. They should initially be recorded at the same value as other patients. (This determination should occur approximately when service begins, but often the determination happens during or after service—such as after receiving a charity care application.) Charity care determination or documented presumptive eligibility per HFAL Policy. |
| 5 | What primary payors should FIDA and FIDA-IDD dual-eligible encounters be assigned to? | Due to the change in the Medicaid DSH Cap calculation in the CMS Third Party Payor Final Rule, FIDA and FIDA-IDD dual-eligible encounters are to be assigned to the Medicare HMO primary payor in ICRs submitted for Report Year 2022 and later. |
| 6 | What primary payors should Medicaid Pending, Medicaid Applied For or similar encounters be assigned to? | Due to the change in the Medicaid DSH Cap calculation in the CMS Third Party Payor Final Rule, if an encounter has no item covered by another third-party payor and the patient has applied for but not yet been approved for Medicaid coverage for any part of the encounter, then it is to be reported within the Uninsured/Self-Pay primary payor. If Medicaid coverage is received, then see the next Question. |
| 7 | In what circumstances, such as later coverage determination, may a change in the primary payor be appropriate? | The Primary Payor is expected to be set at the encounter start; however, there are circumstances where the hospital may, but is not required to, update this because the apparent payor was changed. For example, this includes: when a payor reports retroactive coverage; when the hospital judges that an encounter THAT IS NOT COVERED BY A THIRD-PARTY PAYOR is fully charity care; or when the wrong payor was identified. Primary payor changes are not to occur as the account cascades from a valid primary payor to secondary payors, including self-responsible. |
| 8 | What is the definition of expense related to an interest rate swap? | As with any hedge, interest rate swap contracts vary. Financial institutions incur costs in making and providing these swaps, therefore, hospitals encounter initiation and ongoing maintenance fees and costs for the hedge (swap). These costs may include interest at the fixed-rate that is in excess of the floating (variable) rate, especially early in the arrangement while the variable rate is temporarily frozen or has not risen much. When a financial arrangement includes an interest rate swap, the hospital is expected to identify the costs of the swap and report them properly in any Federal healthcare program cost report. In addition to excluding stated fees and costs and additional interest expense when the fixed-rate exceeds the variable rate, this may require the hospital to adjust reported costs with the implicit value of the swap arrangement, if not explicitly stated in the contract.
Hospitals ' methods for recording transactions also vary, therefore there is not a single approach to how and where within the financial reporting system they are reported. The Department suggests that the controller or CFO can provide insight into the local method(s) applied and underlying contracts. |
| 9 | For Exhibit 30, Line 60, Dual-eligible, what meant by "A payor on the account"–are these Medicaid paids or Eligible for payment? | Hospitals should identify encounters with Medicaid coverage in addition to other coverage in a manner consistent with their Medicaid DSH reporting. |
| 10 | What approval is needed to change the ICR Schedule 1B basis from visits to charges? | If a provider has utilized visits as a transfer basis statistic in the prior year, they may change to charges in the current year with no prior approval. Once an ICR has been submitted with charges used as the basis to determine transfer costs, the provider will no longer be permitted to change back to visits. The change is made for the service area on Exhibit 31A. |
| 11 | If the 2021 Software indicates that, for a service area (Emergency, CPEP Emergency Service, CPEP Observation Beds or Clinic), "Charges" was the prior-year allocation basis, what options are available? | ICR Schedules 1B compute the amount of routine and capital costs transferred to and from four outpatient service areas. The three historical service areas (Emergency, CPEP Emergency Service and Clinic) computed in ICR Schedules 1B are based on either the Exhibit 31A visits or Exhibit 46 charges reported in the ICR. During 2020, CPEP Observation Beds transitioned to an outpatient service only (Exhibit 33 reporting) and an ICR Schedule 1B was established for which all hospitals' bases are charges.
If the previous year basis was charges, then for that service area in the 2020 and later ICR: Exhibit 31A will not be available and ICR Schedule 1B will only present transfers based on charges. |
| 12 | Where should Hospice days reported on S-3 part I line 24.10 or another Hospice line be reported as it relates to Exhibit 32? Are Hospice Days considered ALC? | No, Hospice days are not considered ALC. Hospice is a program that provides care to terminally ill individuals that focuses on easing symptoms rather than treating disease. The hospice benefit is not an Inpatient hospital service unless the patient is admitted as a hospital (not Hospice) inpatient. Therefore, Exhibit 32 should not include days paid for "General Inpatient Care" and "Inpatient Respite Care" for Hospice services.
NYCRR Title 10, Section 86 -1.15 (h) defines Alternate Level of Care services as "those services provided by a hospital to a patient for whom it has been determined that inpatient hospital services are not medically necessary, but that post-hospital extended care services are medically necessary, consistent with utilization review standards, and are being provided by the hospital and are not otherwise available." Third-party payers often term these "custodial care" services. |
| 13 | Are we to carve the amounts on Exhibit 46 lines 382, 386, 383 and 391 out of the allowances where they would normally be reported under primary insurance? | Because of the Report Year 2019 change in reporting HFAL reduction, an example using Third-Party is as follows:
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| 14 | How are charges written-off (reduced) because of the hospital Financial Aid Law (HFAL) Policy to be reported in Exhibit 46? | Because of the Report Year 2019 change in reporting HFAL reduction, an example using Third-Party is as follows:
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| 15 | Are we to report lines 382, 383, 386 and 391 based on accrual or actual write-offs? | The Department expects the accounting basis of amounts reported on lines 382, 383, 386 and 391 to be consistent with that for the remainder of Exhibit 46. |
| 16 | What changes are required for drugs paid outside the rate code? | At this time, for ratio-of-cost-to-charges (RCC) development, ICR Instructions require adjustment as paid outside the rate only of the amounts of all patients' outpatient chemotherapy drug costs in Exhibit 11 and charges in Exhibit 51 (Please refer to ICR instructions). Should the initial cost for Exhibit 11 be entered into a cost center other than Cost Center 123, the hospital should make adjustments or reclassifications to align the cost center of the automatic adjustment with underlying costs and charges. |
| 17 | What professional services may be reported within the Exhibit 50 HFAL costs (charges) and payments? | Professional services that are discretely billed are to be excluded from Exhibit 50 costs/charges and payments. If the hospital billed a global charge and it could have billed the professional and technical components separately, then the charges (costs) and payments for the professional component are to be excluded from Exhibit 50. (Services paid under the FQHC and RHC fee schedules are generally exceptions because the professional component cannot be separately billed for providers that receive the full FQHC/PPS rate.) |
| 18 | Since Rural Health Clinics (RHCs) are paid under the all inclusive rate and professional cost is left in allowable expenses, do professional charges need to be backed out on Exhibit 51? | If the provider has elected to be reimbursed the NYS Medicaid FQHC rate for their RHC(s) (reported on CMS line 88 and subscripts thereof) and the provider has included the professional charges on Exhibit 46 then no adjustment is required on Exhibit 51. |
| 19 | Do school of nursing non-comparable costs include other allied health education programs? For example, school of radiology or pharmacy residency program. | No, although Medicare reporting for Nursing Programs (Schools of Nursing) and allied health education programs are similar, NY State only computes non-comparable amounts for Schools of Nursing. |
| 20 | When will the 2023 RHCF-2/4 report be due? | Any questions regarding reporting or submission of the RHCF cost reports should be directed to the Bureau of Nursing Home and Long-Term Care Rate Setting at rhcf-hcs@health.ny.gov. |
| 21 | What should be done when the HFS MCRX software identifies a non- fatal edit? | Non-fatal errors (4xxxx) and Informatory messages (5xxxx) point out unusual conditions or amounts in the ICR Edit Report. If any inputs that caused the edit are incorrect, please correct the inputs, save and run the Calculate function. This may clear the edit. If an edit is to remain, the Edit Report explanation is to provide insight about why the unusual situation need not be changed. |
| 22 | How should the Health Care and Mental Hygiene Worker Bonus Program (HWB) be reported? | The amounts received by ALL Hospitals for the HWB Program are to be reported at Exhibit 27, Lines 212-214. (This might require an Exhibit 28, Reconciliation to the Audited Financial Statements entry.)
Because these are not allowable amounts for rate-setting, make Exhibit 12 Reclassifications to Cost Center 003 from the cost centers where recorded when paying the HWB to employees. Then make one or two Exhibit 14 All-payor Adjustments to Cost Center 003 to remove this cost, depending on how cost was recorded. If the hospital included HWB payments in the balance sheet, ensure there are no amounts in the Exhibit 11 trial balance, after adjustments. |
| 23 | For ICR Exhibits 32, 33 and 34 reporting, does the Uncompensated Care Collection (UCC) amount include the uninsured HCRA surcharge? | Based on the latest Department guidance, provided for the 2019 Medicaid DSH Audit, that "Per the Preamble to the 2008 DSH Final Rule regarding provider health care taxes, the Department of Health (DOH)'s position for the Medicaid DSH Audits has historically been that payment amounts cannot be offset by the amount of the HCRA surcharge. Therefore, hospitals should not reduce their payments amounts by the HCRA surcharge.", the reported UCC should include the HCRA surcharge. |
| B. Software Questions | ||
| 24 | What is the username and password to download the ICR Software? | The 2023 ICR Software is available to download from the Health Financial Systems (HFS) website. The link is available within the Hospital ICR application of the Health Commerce System (HCS) secure website. |
| 25 | We have already started entering 2023 data. Will we have any problems saving our work once the updated software is installed? | There should not be any problems with saving work once the 2023 HFS software updates have been applied using its Report Wizard. Please note that where the ICR Instructions, entry or Exhibit definitions have been modified, the hospital should verify that previously entered amounts are still accurate and properly reflect the revised ICR. |
| 26 | What ICR software should be used? | 2021 ICR resubmissions should use the Compu-Max Software. 2022 ICR resubmission should use the Compu-max Software at least until the HFS MCRIF32 Software is released for ICR Submission. The Department will advise when it can receive ICR submissions prepared with the MCRIF Software. If this impacts 2022 ICR submissions, this will be communicated. 2023 ICR submissions should use the HFS MCRIF32 Software. The Department will communicate when to start submitting these ICRs through the HCS using the new software. |
| C. Audit Fee Questions | ||
| 27 | What are the fees associated with submitting an ICR? | The ICR audit fees are based on Exhibit 11, column 3, line 960 total expenses at Class code 00042, line 960 of the previous year's report. The audit fee levels are posted on the DOH website. For cost report audits for years 2023 and prior, the audit fee payments have been based on the above costs at the following fee amounts:
<$50 million - $ 5,000 fee $50 - $100 million - $ 7,500 $100 - $300 million - $10,000 $300 - $700 million - $15,000 $700 - $1 billion - $20,000 $1 - $1.5 billion - $30,000 >$1.5 billion - $40,000 |
| D. ICR Audit Questions | ||
| 28 | Is the Hospital Financial Assistance Law (HFAL) questionnaire used solely to determine compliance? Are hospitals field audited on HFAL compliance? | All hospitals' questionnaire responses are used to determine HFAL compliance and are used during the ICR desk audit process. Hospitals selected for ICR field audits have additional procedures performed to complete the HFAL compliance determination. |
| 29 | If a hospital is not found to be in substantial compliance with the HFAL, how long does it have to correct the issue? | As with any ICR Audit finding, for an HFAL non-compliance finding, the hospital is to provide a corrective action plan (CAP) with a "completed-by" date for the Final Audit Dashboard. The Department has the final determination in whether this CAP results in compliance and its timing is appropriate. |
| E. General Questions | ||
| 30 | How is the information in cost reports used by the Department? | The data in the report is used by the Department for data analysis, rate development, the Upper Payment Limit calculation, Disproportionate Share calculation and development of fund distributions. Certain data elements in the ICR are also used by other Agencies. |
| 31 | Will the DOH accept an electronic CEO signature page at some point like the Medicare Report does? | There are internal discussions on the possibility of moving to an electronic certification. However, at this time, we will continue to collect signed CFO certifications in PDF format. |
| 32 | Who should I contact with ICR related questions? | ICR questions can be answered using the following emails:
General ICR Questions : Hospital.ICR@health.ny.gov KPMG ICR Audit Contact: us-albadvnysdhicr@kpmg.com. Audited Financial Statements must be emailed in pdf format to: AFS@health.ny.gov Other resources include: Hospital Inpatient or Outpatient Article 28 rates: HospFFSUnit@health.ny.gov Hospital Outpatient Services for Article 32 (OASAS), Article 31 (OMH) & Article 16 (OPWDD) providers or rates Medicaid Managed Care Rates: bmcr@health.ny.gov Residential Health Care Cost Reports: rhcf-hcs@health.ny.gov Accounts Receivables and Recoupment: bimamail@health.ny.gov The payoff or collection process for a liability balance: mfm@health.ny.gov HCRA and Cash Assessment: hcraprov@health.ny.gov Establishment of locations on eMedNY: providerenrollment@health.ny.gov Billing questions: eMedNY Call Center: 1-800-343-9000 |
