Is your facility in compliance with the current process for Medicare crossover bad debts? If not, it might be time for a refresher!
On April 4, 2019, CMS clarified that, to claim Medicare Part A coinsurance and deductibles as Medicare bad debt, providers must record the write-offs for those accounts to an expense account for uncollectible amounts (bad debt/credit loss expense) and not to contractual adjustments. This clarified position has been effective for all cost-reporting periods beginning on or after October 1, 2019.
Consider reading our corresponding Fine-Tuning Checklist to give your process for collecting coinsurance and deductibles, and claiming the unpaid amounts as Medicare bad debt, a tune-up. The Medicare Administrative Contractors’ (MAC) review policy for bad debt now includes determining whether the claimed amounts were expensed to a bad debt expense account. With this focus, it’s important the individual amount written off can be easily traced to the bad debt expense account. This might include writing off the specific amount with an individual description for each patient in the journal entry. Also, consider segregating bad debts related to Part A coinsurance into a separate general ledger account to help facilitate tracking amounts due from Medicare.
If your organization currently records an estimate for dually eligible (Medicare Part A and Medicaid) beneficiaries’ coinsurance amounts on the balance sheet, which will be collected through the Medicare Cost Report, this can still be accomplished with a separate entry once the Medicare reimbursable bad debt expense is recognized.
If the organization is receiving pass-through payments or lump-sum adjustments as an estimate of bad debt reimbursement claimed on a future cost report, those should be recorded in the estimated amounts due from the Medicare receivable account on the balance sheet, to offset the expected reimbursement for bad debts written off during the year. Doing so will more accurately reflect the amounts due from Medicare upon submission of the cost report.
For revenue recognition, the uncollectible accounts (bad debt/credit loss expense) should be grouped as net revenue. Similarly, the amount that will be collected through the Medicare bad debt process on the Medicare Cost Report will be grouped with net revenue.
If you have questions, reach out to a professional at Forvis Mazars.