Occupational Mix Survey–Preparing for the CY 2025 Cycle Webinar

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Highlights of this episode include:

• What is the Occupational Mix Survey
• When the survey is due
• Which hospitals must complete the survey
• What tools will providers need to complete the occupational mix survey
• Best practices
• Common missteps or issues

Kelly Wisness: Hi, this is Kelly Wisness. Welcome back to the award-winning Hospital Finance Podcast.  We’re pleased to welcome back reimbursement manager, Cody Bales. In this episode, Cody will provide us with a glimpse into BESLER’s next free Webinar, Occupational Mix Survey: Preparing for the CY 2025 Cycle that we’re hosting live on Wednesday, February 18, at 1 PM Eastern Time. Welcome back and thank you for joining us, Cody.

Cody Bales: Thanks for having me on, Kelly.

Kelly: Well, let’s go ahead and jump in. So, what is the Occupational Mix Survey and why is it important?

Cody: Well, the Occupational Mix Survey is a form that CMS requires providers to complete every three years. The survey requires reporting of salaries and hours primarily for the nursing staff, broken down into different categories. RNs, LPNs, and surge techs, nursing assistants and orderlies, and medical assistance. The current ACMX cycle will require wage data specifically from calendar year 2025. So, CMS then takes the data from the survey and calculates an overall nursing cost based on the dollars and hours for each nursing category. This basically is a blended average hourly rate for the nursing staff that is then compared to the national nursing average hourly rate.

And from there, CMS develops what’s called the occupational mix factor, which is a value that can be greater or less than one. This factor will then come in as a positive or a negative adjustment to the provider’s existing wage index data. And since, as I mentioned, the survey is only completed once every three years, once this factor is in place, it remains there for three years until the next cycle. So, the ACMX factor is incredibly important, and it really has the potential to greatly impact the hospital’s final wage index, which as we know is a major, major component of the overall payments that hospitals get from Medicare.

Kelly: So, when is the survey due?

Cody: Well, as we’re speaking today, CMS has not officially announced the due date for the calendar year 2025 survey. But traditionally, the ACMX timeline has been very consistent. So, we’re kind of pretty confidently anticipating that the survey will be due around June 30th of this year. That being said, due to the complexity involved in obtaining accurate data for the survey, providers should really be working on the survey now or sometime soon.

Kelly: Yeah, it sounds like it. That’s going to be here before we know it. So which hospitals must complete the survey?

Cody: The survey is required for essentially all IPPS hospitals. So that would, of course, exclude your critical access hospitals and other non-hospital types of providers.

Kelly: Okay, makes sense. So, what tools will providers need to complete the occupational mix survey?

Cody: The main data source is, of course, going to be a payroll report for your calendar year 2025. This will need to include dollars, and hours, and importantly job description or job title for all employees in the organization, not just the nursing staff. The report will also need to include departments or cost centers, which will impact where or if certain amounts are reported on the OccMix survey. So, providers will need to be able to map those departments in the same way that they do for cost reporting and for from wage index. And then most importantly, probably the reimbursement team will really need to be able to understand the roles or job titles from that internal reporting and determine which, if any, category of nursing that particular job should fall into for reporting on the survey. So this will really require a fundamental understanding of job titles and responsibilities and how each role fits in with the nursing team and the organization.

Kelly: Wow. Sounds like a lot of work and sounds very complex. So, with that in mind, do you have any best practices you can share with providers completing the survey?

Cody: Sure. To start with, it’s essential after you run, and you have the payroll report that you reconcile that to general ledger salaries for the same time period, calendar year 25. That may seem a bit obvious, but it can get overlooked. This helps ensure that the payroll report that you have is a proper basis for the survey. Another is really just to plan ahead and allow plenty of time to understand and properly categorize job titles and employees. This can and probably will necessitate working with HR, payroll personnel, and likely even nursing department directors. So, with that number of people potentially involved, again, it’s a good practice to allow time for questions to get ironed out. I would also mention that the RN personnel in particular should be carefully reviewed when preparing the survey. An employee that has RN and their job title will not necessarily go straight into that bucket on the survey. As the regs outlined, for example, that RNs who function purely in an administrative role would instead be reported in the quote-unquote “other” category on the survey. Additionally, RNs that are advanced practice providers, so think nurse practitioners, certified nurse midwives, CRNAs. Those should also not be reported in the RN bucket on the survey, and instead be excluded. So, to reiterate, it’s essential to be really diligent in reviewing the RN staff in particular.

Kelly: Wow, well, thanks for sharing those best practices with us. We do love those here. So, are there any common missteps or issues that tend to come up?

Cody: Yeah, I can mention a few. One is to ensure that contract labor is being fully accounted for. Contract labor is part of the survey. So, preparers often will go directly to obtaining the activity for the contracted nursing staff, so the agency nurses and so on, while really sometimes neglecting the other non-nursing vendors as the underlying data can be more difficult to pin down. All contract labor should be reported. And depending on the provider’s blend of staffing, excluding that, that non-nursing labor, can actually have a detrimental effect. It’s also important to not overlook reclasses that might be necessary for the survey. This can especially be a problem for those providers out there with non-calendar year ends as you have to really sit down and consider all the salary reclassifications that are utilized for the Medicare cost report when it’s again potentially on a different time period. So again, the step there is to take those, apply those same reclassifications to the calendar year data for the OccMix survey. And the last one that I’ll mention is that if the facility has any excluded type units, which would include psych or rehab units, any non-reimbursables, then it’s important to properly calculate that overhead portion that’s going to be applicable to those areas and then exclude that piece from the survey. So that would be in keeping with the wage index methodology. It really isn’t entirely obvious from the survey itself that that step needs to be performed. And so, it sometimes gets missed.

Kelly: Well, thank you for sharing those with us. And thank you so much for joining us, Cody, and for giving us this sneak peek into BESLER’s upcoming Webinar, Occupational Mix Survey: Preparing for the CY 2025 Cycle that you’re presenting live on Wednesday, February 18, at 1 PM Eastern Time. And as a bonus, you can earn CPE. Thanks again, Cody.

Cody: Thanks, Kelly.

Kelly: And thank you all for joining us for this episode of The Hospital Finance Podcast. Until next time…

If you have a topic that you’d like us to discuss on The Hospital Finance Podcast or if you’d like to be a guest, drop us a line at update@besler.com.

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