Hospitals: Physician Time Studies During the COVID-19 PHE

Published 05/15/2020

Hospitals that incur physician compensation costs must allocate those costs based on the percentage of total time spent furnishing:

  • Part A services
  • Part B services
  • Non-Medicare allowable activities

Hospitals must submit physician allocation agreements annually as part of the cost report filing process. During the Public Health Emergency (PHE), any one of these time study options is acceptable:

  • One week time study every 6 months (two weeks per year)
  • Time studies completed in the cost report period prior to January 27, the PHE effective date. (e.g. hospital with a 7/1/2019 to 6/30/2020 cost reporting period, could use the time studies collected 7/1/2019 through 1/26/2020; no time studies needed for 1/27/2020 to 6/30/2020)
  • Time studies from the same period in CY 2019 (e.g., if unable to complete time studies during February through July 2020, use time studies completed February through July 2019)

For more information see the Provider Reimbursement Manual.

  • Chapter 21,section 2182.3.E.3 — allocation agreements
  • Chapter 23, section 2313.2.E and Chapter 21, section 2182.3.E — instructions for time studies

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