Wheaton Franciscan Healthcare, Shaw, Kenneth--WI

The 2014 proposed rate indicates that the data used for factor 3 includes total T19 days . The T19 days relate to cost report 2010 and or 2011..Both 2010 and 2011 cost reports in many cases have not been audited . In almost all cases the cost reports have not been finalized for 2010 and 2011 . This is due to the SSI ratio issue.We urge CMS to allow the proivder community to have the ability to adjust the Factor III medicaid day totals. In many cases the T19 days presented in the as submitted cost report is very different from what is present in the finalized cost report.In addition the final rules do not indicate which time period is used (2010 or 2011)to determine the medicaid days. The 2014 proposed rules should be clear on which cost reporting year 2010/2011 the T19 days were obtained from regarding factor III. If the T19 days have not been audited for either 2010 or 2011 then the provider should have the ability to correct factor III at a later date.