FY 2019 Wage Index

All requests from hospitals for corrections to their FY 2019 wage index data must be submitted to and received by their Medicare Administrative Contractors (MACs) on or before February 16, 2018. 

The requests and supporting documentation should be sent to the following:

Via email: JJWAGEINDEX@palmettogba.com

Via courier:
Wage Index Revisions
Provider Audit (AG-390)
2300 Springdale Drvie, Bldg One
Camden, SC 29020-1728

Hospital Requests for Corrections to the Wage Index Data
As noted in the wage index development timetable, hospitals may request:

1. Corrections to errors in the early January/late February 2018 PUF due to CMS or MAC mishandling of the wage index data; and
2. Corrections to MAC desk review adjustments included in the early January/late February PUF

No newly initiated wage data revisions will be accepted by the MACs at this point, as it is too late in the process for the MACs to timely handle new data. A hospital that wishes to correct its data under these criteria must submit its request along with complete appropriate detailed documentation to the MAC’s office no later than February 16, 2018. Note that February 16 is the deadline for the MACs’ receipt of correction requests from hospitals. Requests postmarked by February 16, but not received until after February 16, are unacceptable.

All hospitals are required to verify the accuracy of their wage data in the late January/early February PUFs. The February 16 deadline is the final opportunity for hospitals to request corrections to their wage index data before we post the final wage index files on April 27. After the April 27 PUFs are posted, changes to the wage index data will be limited to only situations involving errors by CMS or the MACs that the hospital could not have known about before CMS’s release of the April 27 final PUFs.

If a hospital disagrees with the MAC’s resolution of a requested change, the hospital may appeal to CMS (via letter and electronic copy, and send a copy to the MAC) in an effort to resolve policy disputes. Any such appeal must be made by April 5, 2018, in order to allow time for consideration, and must clearly identify the policy issue involved. As specified in the FY 2019 wage index development timetable (attached for your convenience), the hospital’s letter must be received by CMS (and a copy received by the MAC) by this date.

Also, per the wage index timeline, hospitals shall send to CMS an electronic and a hard copy of the appeal with complete documentation supporting their request (see the FY 2019 wage index timeline for complete details). CMS will not consider matters pertaining to the adequacy of supporting documentation. MACs are in the best position to evaluate matters regarding the adequacy of cost data and cost finding, and these matters should be resolved earlier in the cost reporting process (the cost reporting periods ended nearly two years ago).

NEW: Effective with the FY 2019 wage index, CMS instituted an additional appeals process for hospitals to appeal data corrections made by CMS after posting of the January Public Use File (PUF). To allow input from hospitals concerning corrections made by CMS after the posting of the January PUF that do not arise from a hospital request for a wage data revision, hospitals would use the soonest approaching appeal deadline to dispute any adjustments made by CMS.

However, if a hospital was notified of an adjustment within 14 days of an appeal deadline, the hospital would have until the next appeal deadline to dispute any adjustments. That is, for any adjustments made by CMS after January 30, 2018, the date the January 30, 2018 PUF is posted, and at least 14 calendar days before the April appeals deadline of April 5, 2018 (i.e., March 22, 2018), hospitals would have until April 5, 2018 to dispute those adjustments. For any adjustments made by CMS between 13 calendar days before the April appeals deadline (March 23, 2018) and 14 calendar days before the May appeals deadline (May 16, 2018), hospitals would have until the May appeals deadline (which is May 30, 2018 in the FY 2019 Wage Index Timetable) to dispute the adjustments. In cases where hospitals disagree with CMS adjustments of which they were notified 13 calendar days before the May appeals deadline (May 17, 2018) or later, the hospitals could appeal to the PRRB with no need for further review by CMS before such appeal.

CMS has revised the attached FY 2019 Wage Index Timetable as follows:
 
April 5, 2018
Deadline for the following:

1. Deadline for hospitals to appeal MAC determinations and request CMS’ intervention in cases where the hospital disagrees with the MAC’s determination. It should be noted that during this review, CMS does not consider issues such as the adequacy of a hospital’s supporting documentation, as CMS believes that the MACs are generally in the best position to make evaluations regarding the appropriateness of these types of issues (which should have been resolved earlier in the process). The request must include all correspondence between the hospital and MAC that documents the hospital’s attempt to resolve the dispute earlier in the process. Data that was incorrect in the preliminary or January wage index data PUFs, but for which no correction request was received by the February 16, 2018 deadline, will not be considered for correction at this stage. 
   
2. NEW: The deadline for hospitals to dispute data corrections made by CMS of which the hospital is notified after the January 30, 2018 PUF and at least 14 calendar days prior to April 5, 2018 (March 22, 2018), that do not arise from a hospital’s request for revisions. 

May 30, 2018
Deadline for the following:

1. Deadline for hospitals to submit correction requests to both CMS and their MAC to correct errors due to CMS or MAC mishandling of the final wage and occupational mix data as posted in the April 27, 2018 PUF. Changes to data will be limited to situations involving errors by CMS or the MAC that the hospital could not have known about before review of the final April PUFs.
    
2. NEW: The deadline for hospitals to dispute data corrections made by CMS of which the hospital is notified on or after 13 calendar days prior to April 5, 2018 (March 23, 2018), and at least 14 calendar days prior to May 30, 2018 (May 16, 2018), that do not arise from a hospital’s request for revisions. (Data corrections made by CMS of which a hospital is notified on or after 13 calendar days prior to May 30, 2018 (May 17, 2018) may be appealed to the Provider Reimbursement Review Board (PRRB).

The revised FY 2019 Wage Index Timeline is attached and is also posted on CMS’ website.