CMS periodically updates its forms to improve reporting accuracy, compliance, and transparency. The CMS 2540-24 form replaces CMS 2540-10 beginning with provider reporting periods ending on or after September 30, 2025. Providers may need to make changes within their financial systems to meet form requirements. Implementing these changes efficiently in the general ledger (GL) and accounts receivable (AR) modules is crucial to help ensure regulatory compliance and data integrity. This article outlines practical steps to help providers incorporate CMS 2540-24 form changes into their systems.
1. Review & Analyze CMS 2540-24 Form Updates
- View our FORsights™ article, “The SNF Medicare Cost Report Is Changing – Is Your Facility Ready?” highlighting the key changes in the new updated 2540-24 form.
- The complete, updated CMS 2540-24 form and instructions are downloadable from the official CMS website.
- Identify changes affecting financial systems.
- Compare the new form to the previous version to pinpoint additions, deletions, or modifications to various data input fields.
- Note changes in reporting requirements, cost centers, or account classifications relevant to the GL and AR modules.
- Include representatives from finance, compliance, and IT as applicable in the review process to make sure all perspectives are considered.
2. Map Form Changes to System Requirements
- Update Chart of Accounts
- Revise the chart of accounts in the GL to reflect new or modified cost centers, account codes, and classifications.
- Notable changes for expense tracking include, but are not limited to:
- Contracted labor costs are to be reported separately as a component of total labor costs by cost center; therefore, you should review your chart of accounts to adequately capture contracted expenses for each reported cost center as applicable.
- Added cost centers to report the following expenses separately:
- Quality Assurance and Performance Improvement Program
- Training and In-Service Education
- Patient Transportation Part A
- Radiology now split between Diagnostic and Therapeutic/Chemotherapy
- Drugs charged to patients
- IV Solutions
- Outpatient Lab
- Portable X-Ray
- Preventive vaccines
- Notable changes for expense tracking include, but are not limited to:
- Revise the chart of accounts in the GL to reflect new or modified cost centers, account codes, and classifications.
- Adjust AR Module Configuration
- Make sure that AR module parameters align with new reporting for payor types and ancillary charges, such as:
- Medicare Advantage/Medicare health maintenance organization (HMO) revenues should be tracked separately from commercial insurance revenues. As a reminder, Medicare Advantage/Medicare HMO plans are for individuals 65 and older and eligible for Medicare, while commercial insurance policies are typically for individuals under 65 who have no Medicare eligibility.
- Make sure that AR module parameters align with new reporting for payor types and ancillary charges, such as:
- Define Data Mapping
- Document how form fields correspond to GL and AR system fields for accurate data integration and reporting. For example:
- Verify that the GL chart of accounts allows for tracking Medicare Advantage/Medicare HMO revenues separately from commercial insurance and that the AR module is correctly mapped to the new GL chart of accounts.
- Document how form fields correspond to GL and AR system fields for accurate data integration and reporting. For example:
3. Plan & Execute System Changes
- Develop Implementation Timeline
- Coordinate and schedule system updates to reduce disruption to daily operations.
- Configure System Updates
- Modify GL and AR modules to incorporate new accounts, reporting structures, and mapping as required by the revised form.
- Validate that changes do not adversely impact existing processes or historical data.
4. Educate Staff & Update Documentation
- Educate finance, accounting, and billing staff on new procedures and system changes.
- Accounts payable (AP) invoice coding for new GL accounts.
- Revise Process Documentation
- Update internal manuals, workflows, and processes to reflect new reporting requirements.
5. Monitor Compliance & Refine Processes
- Conduct Post-Implementation Reviews
- Monitor the first reporting cycles for accuracy and completeness.
- Solicit Feedback
- Gather user feedback to identify pain points or areas for further improvement.
- Refine Processes
- Make adjustments to system configurations and procedures as needed to help ensure ongoing compliance.
Conclusion
Adapting the GL and AR modules to accommodate CMS 2540-24 form changes requires detailed analysis, precise mapping, and subsequent review of financials. Following these practical steps can help your organization maintain compliance, improve reporting accuracy, and streamline financial operations in response to regulatory updates.
If you have questions or need assistance, please reach out to a Senior Living & Long-Term Care professional at Forvis Mazars.