2025 Institutional Cost Report (ICR)

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

ICR ROAD SHOW - APRIL 8, 2026

Agenda

Software and Support

➣ HFS MCRIF32 Software

  • 2025 Institutional Cost Report (ICR) and Medicare Cost Report (MCR) Submissions
  • Used for 2022 and forward reportin
  • Initial release of 2025 software will be communicated to providers

➣ Obtaining Software and Support

  • ICR support, problem resolution and questions:
    • Send email to: Hospital.ICR@health.ny.gov
    • Subject line: "2025 ICR - hospital name"
    • For problem resolution, send ".mcrx" file to this email address; file will be forwarded to HFS, if necessary
      (Note: Please do not send files via secure email)

Filing Procedures

  • ➣ Electronic Filing Procedures & Documentation
    • DH file: Electronic submission through Health Commerce System (HCS) - "Hosp Institutional Cost Rpt" application):
      • Due date: Monday, June 15, 2026 (ICR ONLY)
      • Verify the software version used to create the DH file is the latest version accepted by DOH before uploading your file to the HCS
    • Supporting documents due within 5 business days of ICR submission to be considered a valid cost report submission
      • Signed CFO/CEO certification (verify Document Control Number (DCN) matches ICR)
      • Audited Financial Statements (Final) - "Draft" statements not acceptable for audit purposes
    • Audit Fee Form (Proof of Payment)
  • Email supporting document 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:
      • ✤ File named with 7-digit operating certificate number and "_AFF"
        • Example: 1234567_AFF
      (Note: Please do not send any of these files via secure e-mail)
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2025 ICR Audit Fees

  • ➣ Audit Fee Payment/Form
    • Due within 5 business days of filing ICR
    • Same banking information as previous years
    • Audit Fee Schedule scale is available on DOH website
    • Email notification to be released for facility-specific audit fees
    • Additional fees may be assessed when # of submissions exceeds 2
    • Email completed Audit Fee Form to: AFS@health.ny.gov
      • One form may be used to report fees paid for multiple hospitals in a system
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Health Commerce System (HCS)

  • ➣ HCS Website
  • ➣ Communication Tool
    • Secure network for posting provider information
    • Important to keep email address current to receive notifications (cost reports, rates, etc)
      • User's responsibility to keep account updated
      • Email list is separate from the DOH public website electronic mailing lists
  • ➣ HCS Help Contact
    • Commerce Accounts Management Unit: 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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2025 ICR Updates

  • ➣ Exhibits (changes, additions & clarifications)
    • Exhibit 9 (Payments to and on Behalf of…Officers…)
      • Instructions clarified for 2025 reporting
      • Includes CEO, CFO, Administrator, etc.
      • When paid by related entity:
        • ✤ Amount distinctly paid to related entity or
        • ✤ Portion of administrative fees paid to related entity
    • Exhibit 30 (Swing Beds)
      • Removed reporting for number of patients
    • Exhibit 32 (Inpatient Days & Discharges by Source)
      • "Other" service area expanded to allow "Newborn Days" and "Newborn Discharges" to be reported separately from "Adults and Pediatrics", where applicable
      • Reporting Clarification for Labor and Delivery Days vs Ancillary Labor and Delivery Days:
        • ✤ Labor and Delivery Days AREincluded (Exhibit 3 - Line 32, ICR Line 612)
        • ✤ Ancillary Labor and Delivery Days are NOTincluded (Exhibit 3 - Line 32.01)
    • Exhibit 33 (Outpatient Utilization)
      • PROS Community Rehabilitation and Support (CRS)
        • ✤ Units of Service: Service Months
          • ✓ Sum service months for the following:
            • Legacy Rate Codes 4520 - 4524 (through 3/31/2025) and
            • New Rate Codes 4516 - 4518 (beginning 4/1/2025)
          • ✓ Exclude the following:
            • Rate Code 4510 (Pre-Admin)
            • Rate Codes 4525 - 4534 (Add-ons)
            • 15-minute increments
      • Note: Costs and revenue should be reported based on ALL PROS services
    • Exhibit 46 (Patient Services Revenue)
      • Variable lines 009 - 012: Provide clinical service description
    • Exhibit 50 (Patient Financial Aid Report)
      • On and after October 1, 2024
      • Only applies to Article 28 general hospitals
        • ✤ Increased eligibility for charity care based on statutory changes
        • ✤ New reporting requirements due to Hospital Financial Aid Law (HFAL) changes
          • ✓ Demographic reporting (applicants)
            • Age, race/ethnicity, gender, insurance status and income level
            • First introduced with the 2024 ICR, but did not affect some fiscal year filers
          • ✓ Presumptive Eligibility reporting:
            • Board-approved policy (may be part of HFAL Policy)
            • Include in "Approved" column
            • Count as ONE application for financial aid (not by number of encounters)
    • ➣ Edits
      • Importance of Edits
        • Improve data integrity
          • ✤ Budgetary Analysis, DSH Model, Directed Payments, etc.
        • Highlight data anomalies
          • ✤ Low utilization, positive values entered as negatives & vice versa, etc.
        • Help reduce ICR audit findings and/or questions
          • ✤ May prevent reporting errors and avoid audit findings
          • ✤ Edit explanations reviewed by DOH and provided to auditors
      • New edits
        • Highlight inconsistencies between reported utilization, costs and/or charges
        • All new edits/changes to edits will be highlighted in the edit listing
      • 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 just 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 a valid explanation
      • Edit Responses
        • Explanations should provide insight
          • ✤ Cannot be left blank (Fatal Edit)
          • ✤ Should not state "Confirmed", except for edits requesting confirmation (ex - EDIT 41806)
            • ✓ Stating "Correct", "Affirmed" or similar are also insufficient
          • ✤ Indicating "Will review during audit" is not acceptable
          • ✤ Edits 43201 (days) and 43206 (discharges): Edits where differences between PS&R for Exhibit 3 and the hospital billing system for Exhibit 32 are expected
          • ✤ Inadequate responses may result in ICR not being accepted by DOH
          Note: Any edits that require reporting corrections should be done BEFORE filing EITHER the Medicare or Medicaid cost report
    • ➣ Primary Payor Reporting
      • 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
        • Hospital Financial Aid Law (HFAL)
          • ✤ Use lines 382, 383, 386 and 391 on Exhibit 46 to report Charity Care reductions
      • Payor changes for later eligibility determination
      • Essential Plan 200-250 as Primary Payor Category
        • Payer category is available in the ICR (initially added for the 2024 ICR)
        • Report if data is available
        • Discrete reporting not mandatory since CMS approved the State's request to revert back to the Basic Health Plan effective 7/1/2026
      • Centers for Medicare and Medicaid Services (CMS)
        • February 23, 2024 DSH Third-Party Payer Final Rule (89 FR 37, pp. 13916-13948)
        • Ensure that Primary payor is being reported appropriately
        • ICR Instructions and/or FAQs updated based on discussions with DSH Team
    • ➣ Reminders
      • 2025 ICR Submissions (Pre-Audit)
        • 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
        • DCN's must match - ICR submission and CFO certification
        • Recommended - submit audited 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 (ICR files to be sent to auditors September 2026)
            • ✓ Wholesale exhibit changes will notbe accepted during the audit
          • ✤ Contact Hospital.ICR@health.ny.gov if a resubmission is necessary before the audit
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      Questions?

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

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