2014 DSH Changes
As required by Proviso 33.34, the SCDHHS is actively working with the South Carolina Hospital Association (SCHA) to enhance accountability for Disproportionate Share Hospital (DSH) payments and to ensure that new DSH formula requirements under the Affordable Care Act (ACA) do not adversely affect the South Carolina DSH pool beyond the statutorily required reduction in the state's DSH cap.
New DSH Policies
Submission of patient account data
The new policy requires that all hospitals (except Department of Mental Health [DMH] hospitals) produce account data for all uninsured patients for whom the hospital has sought DSH reimbursement in its 2014 DSH survey response. The data fields that must be produced are specified in the “Data Field Specifications.” The data should be uploaded at https://msp.scdhhs.gov/DSH/.
Patient account data relating to the 2014 DSH survey must be submitted by April 4, 2014. In future years, patient account data and DSH survey responses must be submitted simultaneously.
Procedures to ensure that the DSH program is the payor of last resort
The new policy requires each hospital (except out-of-state border hospitals and DMH hospitals) provide a certification from its CEO or CFO confirming that the hospital follows SCDHHS’s recommended workflow or an SCDHHS-approved alternative workflow.
SCDHHS recognizes that hospitals may develop different workflows for different areas of their operations. As such, a hospital may submit multiple alternative workflows.
A diagram of SCDHHS’s recommended workflow and an accompanying workflow guide are available. The recommended workflow includes the use of the patient attestation form.
Alternative workflows (and accompanying workflow explanations) and CEO or CFO certification letters should be submitted to SCDHHS at proviso@scdhhs.gov. At a minimum, any alternative workflow must include a discussion of insurance options with the patient and an auditable method of documenting that the hospital has complied with its workflow for each patient.
If an uninsured patient has claims with dates of service more than 90 days apart, a discussion of insurance options must be documented using the attestation form (or any approved alternative) for each 90 day period.
Hospitals must implement SCDHHS’s recommended workflow (or an SCDHHS-approved alternative workflow) and submit a signed CEO/CFO certification of compliance by May 8, 2014.
Resources
- SCDHHS DSH Guidance Letter
- Health Insurance and Coverage Options
- Health Insurance and Coverage Options (Spanish)
- Unisured Patient Attestation
- Unisured Patient Attestation (Spanish)
- Data Field Specifications
- SCDHHS Workflow
- Workflow Guide
- CEO-CFO Certification Template
- FAQs
