IT management

Who this applies to: Those responsible for price transparency reporting, revenue cycle/registration, or contracting at an Inpatient Prospective Payment System (IPPS) hospital or in a reimbursement department at a healthcare facility. 

The Centers for Medicare and Medicaid Services (CMS) introduced Worksheet S-12 to Form CMS-2552-10, adding a new reporting requirement for certain IPPS hospitals. Effective for cost reporting periods ending on or after January 1, 2026, applicable hospitals must report the weighted median Medicare Advantage Organization (MAO) payer-specific negotiated charge by Medicare Severity Diagnosis Related Group (MS-DRG) for inpatient discharges during the cost reporting period.

What Worksheet S-12 measures and why it matters 

Although the worksheet refers to negotiated “charges,” the reported amount is better understood as the negotiated payment rate or estimated payment amount associated with a Medicare Advantage contract for a specific MS-DRG. These amounts generally do not tie directly to the actual payment received on each individual claim. Instead, the worksheet is intended to capture a standardized, discharge-weighted median negotiated amount for each applicable MS-DRG. 

CMS created Worksheet S-12 to collect MS-DRG-specific payment data for use in developing a market-based MS-DRG relative weight methodology beginning in FY 2029. Because CMS has stated that they may refine this methodology through future rulemaking before implementation, hospitals should monitor future rules and related guidance for updates.

Who must complete Worksheet S-12? 

Worksheet S-12 applies to subsection (d) hospitals, including applicable IPPS hospitals and subsection (d) Puerto Rico hospitals. The requirement does not apply to Critical Access Hospitals, inpatient psychiatric hospitals, inpatient rehabilitation hospitals, children’s hospitals, and cancer hospitals. CMS instructions also identify other limited exemptions, such as hospitals that do not negotiate payment rates and only receive non-negotiated payments, as well as hospitals paid under the Maryland Total Cost of Care Model during the model’s performance period.  

Hospitals should carefully evaluate whether they are subject to the requirement before preparing the cost report. Failure to complete the worksheet may result in the cost report being rejected, making early assessment and data preparation important. 

Core data needed to complete Worksheet S-12 

• The hospital’s most recent Hospital Price Transparency Machine-Readable File (MRF) as of the hospital’s cost report filing date, which should include MAO payer-specific negotiated charges 
• Detailed inpatient discharge data from the hospital’s Electronic Medical Record (EMR) or patient accounting system, organized by payer, plan, and MS-DRG 
• Identification of capitated and non-capitated Medicare Advantage plans, because capitated arrangements are excluded from the weighted median calculation but may still be needed for reconciliation and audit support 
• MS-DRG grouping or mapping information, particularly when negotiated charges are not identified directly at the MS-DRG level and must be cross-walked from another classification system 

Why the MFRs matters 

The Hospital Price Transparency MRF is central to Worksheet S-12 because it is the source for the MAO payer-specific negotiated charges. Hospitals should confirm that their file is available, complete, and formatted in a way that allows negotiated charges to be matched to MAO plans and MS-DRGs. If the file is incomplete or difficult to use, the hospital may face significant challenges preparing the worksheet accurately and timely.

Building the discharge detail file 

The discharge detail file should be developed from the hospital’s EMR or patient accounting system and should include one line per inpatient discharge. The file should be based on discharge dates within the hospital’s fiscal year and should include inpatient bill types, such as 11x claims, while allowing the hospital to identify transfers, denied claims, outpatient accounts, and claims pending appeal. 

• Account number or other unique discharge identifier 
• Discharge date 
• Discharge disposition or other indicator used to distinguish true discharges from transfers 
• Financial class 
• Payer plan name 
• Payer plan code 
• MS-DRG 
• Capitation indicator 
• Claim status, including indicators for denied claims, outpatient claims, and claims pending appeal 

A clean discharge detail file is essential because the weighted median calculation depends on matching each applicable Medicare Advantage discharge to the correct negotiated charge. Each discharge should appear on a single line so that the data can be sorted, filtered, reconciled, and matched consistently.

How to calculate the weighted median negotiated charge 

To calculate the weighted median Medicare Advantage payer-specific negotiated charge, the hospital should first isolate inpatient discharges associated with Medicare Advantage plans. The negotiated charge from the MFR should then be matched to each discharge based on the MAO payer and the applicable MS-DRG. If a discharge or negotiated charge is not already identified at the MS-DRG level, the hospital must perform an appropriate crosswalk or grouping process. 

1. Assign each Medicare Advantage inpatient discharge a payer-specific negotiated charge using the MAO plan and coded MS-DRG. 
2. If the discharge is not coded to an MS-DRG, map the applicable classification, such as an APR-DRG, to the appropriate MS-DRG for matching. 
3. Exclude capitated discharges and other accounts that should not be included in the calculation, while retaining them as needed for reconciliation and a solid audit trail. 
4. Sort the remaining records by MS-DRG and negotiated charge from lowest to highest. 
5. For each MS-DRG, identify the median negotiated charge. If the number of discharges is odd, use the middle value. If the number of discharges is even, average the two middle values. 
6. Enter the resulting median negotiated charge on Worksheet S-12 only for MS-DRGs that had applicable discharges during the fiscal year. 

How to prepare for Worksheet S-12 

Hospitals should begin preparing for Worksheet S-12 well before the cost report filing deadline.  

Key steps to take now:  

1. Validate the hospital’s MRF. 
2. Confirm Medicare Advantage payer mappings. 
3. Develop a discharge-level data extract. 
4. Identify capitated arrangements. 
5. Test the median calculation process. 

Early preparation can help reduce filing risk, support reconciliation, and avoid last-minute issues with cost report software edits. 

Because Worksheet S-12 connects Hospital Price Transparency data, Medicare Advantage contracting information, and Medicare cost report reporting, the preparation process will likely require coordination among reimbursement, finance, revenue cycle, contracting, and information technology teams.

Key takeaways

• Determine whether your hospital is required to complete Worksheet S-12 before beginning Medicare cost report preparation. 
• Validate the hospital’s MRF to confirm Medicare Advantage negotiated charge data is complete and usable. 
• Build a discharge-level data file that connects Medicare Advantage inpatient discharges to payer plans and MS-DRGs. 
• Exclude capitated arrangements and other non-applicable accounts from the weighted median calculation while retaining support for reconciliation. 
• Coordinate across reimbursement, finance, revenue cycle, contracting, and IT teams to reduce filing risk and support timely reporting.

About BerryDunn

BerryDunn’s healthcare reimbursement team can help hospitals prepare for Worksheet S-12 by evaluating applicability, reviewing MRF readiness, developing discharge-level data extracts, mapping Medicare Advantage plans and MS-DRGs, and creating a defensible approach to the weighted median calculation. If your organization has questions about this new Medicare cost report requirement or needs support preparing for implementation, we can help. Learn more about our team and services.

Who this article applies to: Compliance officers, revenue integrity directors, clinical documentation improvement specialists, clinical documentation and coding auditors, and healthcare providers at healthcare facilities or medical practices. 

It may feel at times like CPT® (Current Procedural Terminology) coding never changes—until it does. The American Medical Association (AMA) annually updates the CPT code set, with main revisions becoming effective January 1, 2027. These changes often require organizations to rethink documentation, coding, workflows, education, and auditing. CPT coding updates may be sporadic and unique, but early organizational preparation can minimize disruptions.

The impacts of CPT code changes may reverberate well beyond the coding department. Significant CPT revisions can affect the productivity, coding accuracy, denial rates, reimbursement patterns, compliance monitoring, Electronic Health Record (EHR) builds, payer contract assumptions, and audit findings of coding and revenue cycle teams. Even seemingly straightforward code changes can trigger extensive downstream impacts if documentation expectations, charge capture workflows, and system configurations are misaligned. Organizations should therefore approach major CPT updates as cross-functional operational changes, rather than as isolated coding updates, and prepare early. 

One CPT change, organization-wide impact 

The upcoming 2027 obstetric coding changes provide an excellent example of the broad impact code changes can have across an organization. Beginning January 1, 2027, maternity care reporting will undergo one of its most significant changes in decades, bringing an end to the long-used global obstetric package model. The resulting increase in Evaluation and Management (E/M) service reporting will require complete and accurate documentation to support code selection.

This shift to increased E/M coding for obstetric services reinforces an important lesson that is applicable to other service lines. Major CPT revisions, such as for obstetrics, rarely involve code changes alone. In the obstetrical example, use of increased E/M coding will require documentation improvements and EHR template revision, workflow redesign, provider education, and ongoing auditing to ensure compliance with the resulting changes.

Preparation will be especially important for these code sets because many patients receiving antepartum services in 2026 may continue their maternity care into 2027, when the new reporting structure takes effect. Organizations will need to consider how visits, documentation, charge capture, payer requirements, and patient encounters that cross the implementation date will be managed. Without proactive planning, organizations put themselves at increased risk for a cascade of events beginning with incomplete documentation and inconsistent coding, leading to potential delayed claims, payer denials, and confusion among providers and revenue cycle teams. Developing clear guidance before the updated code implementation will help ensure continuity of care, accurate reporting, and a smoother operational transition. 

Six steps to prepare for CPT changes

1. Start planning early. Identify affected specialties, workflows, payer policies, and EHR implications to allow time for meaningful education and implementation of changes. 
2. Engage multiple departments. Build a multidisciplinary workgroup that includes coding, compliance, revenue cycle, clinical leaders, operational leaders, and information technology representatives. 
3. Focus on documentation, not just codes. New codes often introduce new documentation requirements that all clinical staff, coders, providers, and auditors should be aware of. Perform documentation gap assessments to identify where provider education may be needed before the effective date. 
4. Evaluate technology. Validate EHR templates, charge capture tools, coding edits, payer rules, reporting systems, and analytics dashboards prior to January 1. 
5. Monitor performance after implementation. Conduct focused post-implementation audits of documentation, coding accuracy, denial trends, and reimbursement patterns to identify improvement opportunities and provide feedback. Use findings to provide timely feedback and make necessary adjustments.  
6. Communicate consistently. Provide staff and colleagues with regular updates and clear guidance throughout the transition period. Having a clear point of contact gives everyone a reliable resource for questions throughout the transition. 

Plan now for upcoming CPT code changes 

Major CPT revisions rarely involve coding changes alone; rather, they prompt cascading operational changes. Successful implementations occur when coding, documentation, compliance, clinical operations, IT, and revenue cycle teams begin planning well before the effective date. Organizations that start now will be best positioned to maintain compliance, support accurate reimbursement, and minimize operational disruption when the next major CPT update arrives. Now is the time to begin. 

BerryDunn can help  

Our healthcare compliance team can help. We incorporate deep, hands-on knowledge with industry best practices to help your organization manage compliance and revenue integrity risks. Learn more about our healthcare compliance consulting team and services.

Who this applies to: Read this if you are a business owner who accepts credit card payments.

As credit card processing costs continue to rise, many businesses are looking for ways to recover these expenses without significantly affecting profitability. Surcharging, which allows a business to add a fee when a customer pays by credit card, is one option. Dual pricing, which gives customers a choice between a lower cash price and a higher card price, is a second option. Business owners must weigh each option carefully to determine what will best suit their needs.

Surcharging: What you need to know

Most states allow businesses to add a surcharge for credit card payments, provided they comply with card network rules and applicable disclosure requirements. However, surcharging is prohibited or significantly restricted in certain jurisdictions, including Connecticut, Massachusetts, Puerto Rico, and potentially Maine. Several other states, including California, Colorado, New York, Minnesota, New Jersey, Nevada, and Texas, have additional requirements or restrictions that businesses should review before implementing a surcharge. Because surcharge laws continue to evolve through legislation, regulation, and court decisions, businesses should confirm current state requirements before moving forward.

Regardless of state, several card network rules apply. Debit card transactions can never be surcharged. Any surcharge must not exceed the merchant’s actual cost of processing the transaction and is generally capped by the card networks. Businesses must also clearly disclose the surcharge before payment is completed and confirm that their Point-of-Sale (POS) system can properly distinguish between credit and debit card transactions. If your business operates in a state where surcharging is prohibited or heavily regulated, a dual-pricing model may be a viable alternative.

What is dual pricing? 

Dual pricing presents customers with two prices upfront: a lower cash price and a higher card price that reflects the cost of card acceptance. Unlike surcharging, no additional fee is added at checkout. Instead, both prices are disclosed before the customer makes a purchasing decision, allowing the customer to choose their preferred payment method. 

Dual pricing is generally permitted throughout the United States when implemented as a properly disclosed cash-discount program. Businesses should work with their processor and legal counsel to ensure compliance with applicable laws, card-brand rules, and disclosure requirements.

Best practices for dual pricing compliance 

• Establish the card price as the posted price and offer a clearly labeled cash discount. 
• Display both prices prominently on shelves, menus, websites, and other customer-facing materials before checkout. 
• Use consistent signage at entrances, checkout areas, and on receipts. 
• Ensure receipts clearly show the transaction amount and any applicable cash discount. 
• Utilize POS software designed to support compliant dual-pricing programs. 
• Train employees to explain the pricing structure consistently and accurately. 

Customers should always be able to understand the price they are paying and how their choice of payment method affects the final transaction amount.

Addressing rising credit card processing costs 

As credit card processing costs continue to rise, many businesses are looking for ways to manage these expenses without significantly impacting profitability. Both surcharging and dual pricing can help offset processing costs, but each approach comes with specific legal and operational requirements. The key to a successful program is transparency: customers should clearly understand their options and pricing before making a purchase. By working closely with your payment processor, reviewing applicable state laws, and communicating openly with customers, businesses can implement a compliant solution that balances cost recovery with a positive customer experience.

State laws change frequently. Please consult the most current laws for up-to-date information. 

Key takeaways

• Compare surcharging and dual pricing before choosing a way to recover credit card processing costs. 
• Review state laws, card network rules, and disclosure requirements before adding a credit card surcharge. 
• Confirm that your point-of-sale system can distinguish between credit and debit card transactions. 
• Disclose cash and card prices clearly before checkout so customers understand payment-related costs. 
• Train employees to explain the pricing structure consistently and accurately. 

About BerryDunn 

BerryDunn’s outsourced accounting services are tailored to the volume of work you have. Whether you need extra help in your office during peak times or interim leadership support during periods of transition, we can help you. We offer the expertise of a fully staffed accounting department for short-term assignments or long-term engagements―so you can focus on your business. Learn more about our team and services.

Compliance is more than a checklist: it is the foundation of organizational success. Across Medicaid agencies, health plans, healthcare providers, and community organizations, compliance creates the structure and consistency needed to fulfill the mission, protect those served, safeguard public resources, and earn stakeholder trust.

For Medicaid agencies in particular, the importance of compliance has never been greater. As states manage increasing program complexity, evolving federal requirements, heightened program integrity expectations, and growing scrutiny from oversight entities, compliance provides a critical framework for accountability, transparency, and responsible stewardship of taxpayer dollars.

Many organizations view compliance as a regulatory requirement or cost of doing business. In reality, it provides the framework needed to operate effectively, manage risk, and achieve sustainable success. For state Medicaid agencies, this framework is especially important as they operate under continual oversight from Centers for Medicare and Medicaid Services (CMS), the Office of Inspector General (OIG), state auditors, legislatures, and other stakeholders. A strong compliance program helps agencies proactively identify risks, strengthen controls, support program integrity, and demonstrate responsible stewardship of public funds.

A football game without rules, officials, coaches, or clear expectations would quickly become chaotic. Standards, oversight, and accountability do not hinder performance; they create the structure necessary for success. To achieve their objectives, organizations need clear expectations, defined processes, and effective governance. Compliance provides that foundation.

Without it, organizations face greater risk of errors, inefficiency, fraud, waste, abuse, regulatory violations, and reputational harm. Effective compliance supports sound decision-making, promotes consistency, and creates conditions for long-term success.

Putting compliance into practice

Strong compliance programs integrate governance, risk management, communication, training, monitoring, and continuous improvement into day-to-day operations.

At its best, the compliance function is a trusted advisor helping leaders identify risks, strengthen controls, improve performance, and make informed decisions.

Organizations with mature compliance programs are often better positioned to identify risks, adapt to changes, and maintain public trust. For Medicaid agencies, effective compliance programs can also support audit readiness, strengthen oversight of contractors and providers, improve program integrity efforts, and help identify and address issues before they become findings, corrective actions, or larger program risks.

Turning compliance into action

Organizations seeking to strengthen compliance do not need to address every challenge at once. Meaningful progress begins with a few foundational steps:

• Establish accountability. Clearly define compliance responsibilities and ensure leaders and employees understand their role in managing risk and supporting organizational objectives.
• Document expectations. Establish written policies and procedures that provide consistent guidance, support decision-making, and promote operational consistency.
• Foster a culture of compliance. Encourage employees to ask questions, report concerns, and view compliance as a shared responsibility.
• Evaluate and improve. Regularly assess risks, monitor performance, and use lessons learned to strengthen processes, controls, and outcomes.

Compliance is about trust

Compliance builds confidence that public funds are used appropriately, services are delivered responsibly, and decisions are made with integrity and transparency. For Medicaid agencies, that confidence extends to beneficiaries, providers, taxpayers, legislators, federal partners, and oversight entities that rely on the agency to be responsible stewards of public resources.

That trust depends on leadership commitment and ongoing investment in oversight, training, communication, monitoring, and continuous improvement. Compliance cannot reside within a single department. It must be embedded throughout an organization.

As organizations navigate increasingly complex regulatory, operational, and financial environments, leaders should periodically step back and ask:

• Are our compliance activities aligned with our mission and strategic goals?
• Do we have the people, resources, expertise, and infrastructure needed to manage risk effectively?
• Are compliance considerations integrated into decision-making across the organization?
• Does our culture promote accountability, transparency, and continuous improvement?

The answers may reveal vulnerabilities that threaten mission success, as well as opportunities to improve outcomes, strengthen resilience, and better position the organization for the future.

The question for leaders is not whether an organization is compliant today, but whether it has the governance, oversight, and the culture necessary to remain successful tomorrow. When embedded in strategy and operations, compliance becomes a driver of organizational excellence. It transforms mission into action, principles into practice, and strategy into measurable results. Beyond the checklist, compliance enables organizations to lead with integrity, manage uncertainty with confidence, and achieve sustainable success.

The questions posed in this article are intended to start a broader conversation about how compliance supports organizational performance. Future articles will explore practical strategies for strengthening governance, managing risk, developing effective written policies and procedures, and fostering a culture of integrity and accountability. Together, these elements can help organizations move beyond compliance as an obligation and leverage it as a strategic advantage.

Key takeaways

• Recognize compliance as the foundation for organizational success, not just a regulatory requirement or cost of doing business.
• Use compliance to create the structure, consistency, and accountability needed to fulfill the mission and safeguard public resources.
• Integrate governance, risk management, communication, training, monitoring, and continuous improvement into day-to-day operations.
• Strengthen controls, audit readiness, contractor and provider oversight, and program integrity efforts before issues become findings or corrective actions.
• Evaluate whether compliance activities are aligned with mission, strategic goals, decision-making, and the culture needed for long-term success.

BerryDunn’s Medicaid Practice Group helps Medicaid agencies improve the health and lives of individuals by empowering, inspiring, and partnering with our clients—we innovate, share deep expertise, and provide an independent perspective to resolve challenges. We are the success partner for Medicaid agencies, building healthier communities and stronger futures. Learn more about our team and services.

A modest rate increase and CMS's inquiry into PDPM case-mix growth

The Centers for Medicare and Medicaid Services (CMS) issued the FFY 2027 Skilled Nursing Facility (SNF) Prospective Payment System (PPS) Final Rule, which was published in the Federal Register on July 31, 2026.  

The rule updates SNF PPS payment rates effective from October 1, 2026, to September 30, 2027, and includes changes to the SNF Quality Reporting Program (QRP), the SNF Value-Based Purchasing (VBP) Program, and several policy initiatives that may shape future reimbursement. 

While the payment update is relatively straightforward, CMS devoted considerable attention to reviewing trends under the Patient Driven Payment Model (PDPM), signaling continued focus on coding practices and potential future payment adjustments. Providers should pay close attention to this area as CMS evaluates comments received regarding case-mix growth and potential PDPM recalibrations. 

FFY 2027 PPS rate calculations 

CMS finalized a 2.4% payment update for FFY 2027, reflecting: 

• A 3.3% SNF market basket increase 
• Less a 0.9 percentage-point productivity adjustment 
• No forecast error adjustment 

CMS estimates that the aggregate impact of the payment policies in this Final Rule will result in an increase of 2.4%, or approximately $882.7 million, in Medicare Part A payments to SNFs in FFY 2027. These estimates do not include the impact of SNF Value-Based Purchasing (VBP) adjustments, which CMS estimates will reduce payments by approximately $203.6 million. The impact of the update will vary by provider based on wage index changes, geographic location, resident case mix, and facility-specific VBP performance. 

CMS projects an average payment increase of 2.4% for urban SNFs and 2.7% for rural SNFs, with a low of 0.5% for rural Mountain providers and a high of 4.6% for rural New England providers. Actual provider-level impact will vary based on wage index changes and other facility-specific factors. 

The unadjusted federal rates for FFY 2027, prior to adjustment for case-mix, are as follows:  

FFY 2027 Unadjusted Federal Rate Per Diem – Urban 

FFY 2027 Unadjusted Federal Rate Per Diem – Rural 

These rates remain subject to PDPM case-mix adjustments and facility-specific wage index adjustments.

Updated PPS Rate Calculator available

As in prior years, BerryDunn has updated its interactive PPS Rate Calculator within the BerryDunn Senior Living Portal to incorporate the FFY 2027 payment rates and wage index information to assist you with the calculation of your facility-specific PPS rates.

Access the PPS Rate Calculator. 

Please note that calculated rates do not reflect facility-specific SNF VBP adjustments. BerryDunn will update the calculator as necessary once final incentive payment multipliers become available. Meanwhile, VBP information, including the incentive payment modifier for FFY27, has been made available to providers in iQIES. We recommend reviewing data carefully and promptly, as any requests for corrections are accepted by CMS through the end of August. 

CMS focuses on PDPM case-mix growth 

The most notable policy discussion in this year's Final Rule is CMS's continued evaluation of PDPM reimbursement trends. 

CMS previously solicited stakeholder feedback through a Request for Information (RFI) regarding observed increases in certain PDPM coding elements since implementation. Examples cited by CMS include substantial increases in reporting of diagnosis codes that increase PDPM reimbursement, such as malnutrition, swallowing disorders, and depression indicators. CMS noted that these trends have occurred while certain categories of resource utilization have declined.  

The agency presented potential methodologies for measuring what it refers to as "case-mix creep" and sought stakeholder feedback regarding possible future payment adjustments. While CMS did not finalize any PDPM payment reductions in this rule, the methodology discussed in the proposed rule produced a hypothetical system-wide case-mix creep adjustment factor of 0.957, which CMS estimated could equate to a 4.3% reduction in CMIs/base rates or a 3.6% reduction in total payments. Providers should view this discussion as a clear signal that CMS is actively evaluating whether future reimbursement modifications are warranted.  

CMS did not finalize any PDPM-related payment adjustments in FFY 2027. However, organizations should continue emphasizing accurate, well-supported clinical documentation and coding practices. 

SNF QRP update  

CMS finalized several changes to the SNF Quality Reporting Program. 

Removal of COVID-19 measures 

Beginning with FFY 2028 SNF QRP reporting, CMS is removing: 

• COVID-19 Vaccination Coverage Among Healthcare Personnel 
• COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date 
   

CMS noted that evolving vaccination guidance and the move toward individualized clinical decision-making have reduced the usefulness of these measures for quality reporting purposes.  

Shorter data submission deadlines 

CMS finalized changes that will significantly shorten quality reporting submission timelines.  

Beginning with FFY 2029 SNF QRP reporting, providers must submit data by the 15th day of the second month following the end of each calendar quarter, approximately 45 days after quarter-end, replacing the current four-and-a-half-month submission time frame. CMS stated the change is intended to improve the timeliness of publicly reported quality information.  

All-payer MDS reporting requirement 

CMS finalized a requirement that SNFs submit MDS data for all residents receiving covered skilled services, regardless of payer, beginning with the FFY 2031 SNF QRP. This change is intended to align SNF quality reporting with other post-acute care settings and provide a broader picture of SNF quality performance. 

SNF VBP program update  

CMS finalized performance standards for FFY 2029 and FFY 2030, revised the snapshot date for two MDS-based VBP measures to align with the revised QRP submission timeline, and made technical regulatory updates.   

CMS estimates that the SNF VBP Program will result in an approximately $203.6 million reduction in aggregate payments to SNFs nationwide during FFY 2027.

Bottom line for SNFs 

The FFY 2027 Final Rule delivers a modest 2.4% payment increase. 

CMS signaled continued interest in PDPM coding trends and potential future payment refinements. At the same time, providers should begin preparing for accelerated QRP reporting timelines and eventual all-payer MDS submission requirements. 

For most organizations, the immediate next step is understanding the impact of the FFY 2027 rates on facility-specific reimbursement. BerryDunn's updated PPS Rate Calculator can help quantify that impact and support budgeting efforts for the coming fiscal year. 

If you have any questions about the Final Rule or how it might affect your facility, please contact Ashley Tkowski or Melissa Baez.