News & Analysis as of

Off-Campus Departments Outpatient Prospective Payment System (OPPS)

Health Care Compliance Association (HCCA)

CMS to Take Back Money It Returned Under Site-Neutral Payment Policy

Report on Medicare Compliance 30, no. 2 (January 18, 2021) - CMS is taking back money from hospitals for outpatient clinic visits provided in 2019 at excepted off-campus provider-based departments (PBDs) after returning...more

Bricker Graydon LLP

CMS delays activation of systematic validation edits for OPPS providers with multiple service locations until further notice

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On March 24, 2020, the Centers for Medicare & Medicaid Services (CMS) announced a delay until further notice to the activation of systematic validation edits for OPPS providers with multiple locations. After multiple prior...more

King & Spalding

Hospitals Ask Appeals Court to Affirm Their Victory in Off-Campus Provider-Based Department Rate Cut Saga

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On Thursday, February 20, 2020, hospitals represented by King & Spalding that operate excepted off-campus provided-based outpatient departments (PBDs) filed their brief in federal appeals court to preserve the victory they...more

King & Spalding

CMS to Repay Hospitals for 2019 Off-Campus Clinic Visit Services

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CMS and its contractors have announced that beginning January 1, 2020, the agency will repay hospitals for underpaid evaluation and management (E/M) services provided in excepted off-campus provider-based departments during...more

King & Spalding

CMS Publishes Final Rule for CY 2020 Hospital Outpatient Prospective Payment System

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n November 1, 2019, CMS posted the final rule establishing the payment rates for the Hospital Outpatient Prospective Payment System (OPPS) and the Ambulatory Surgery Center (ASC) Payment System for calendar year (CY) 2020...more

Polsinelli

CMS Delays Price Transparency, Doubles Down on Site-Neutral and 340B Payment Policies in CY 2020 OPPS Final Rule

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Late last week, the Centers for Medicare & Medicaid Services (“CMS”) released the CY 2020 Hospital Outpatient Prospective Payment System (“OPPS”) final rule [CMS-1717-FC]. While many hospitals had hoped for relief from recent...more

Baker Donelson

D.C. Court Rejects CMS's 2018 "Budget Neutrality" Policy

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In a September 17, 2019 decision, the United States District Court for the District of Columbia invalidated a CMS rule expanding site-neutral payment reductions to evaluation and management (E&M) services furnished in...more

Katten Muchin Rosenman LLP

Court Invalidates Latest CMS Effort to Reduce Reimbursement at Off-Campus Hospital Outpatient Departments

Key Points - ·On September 17, 2019, the District Court for the District of Columbia rejected the Centers for Medicare and Medicaid Services’ (CMS) latest attempt to limit Medicare reimbursement at off-campus outpatient...more

ArentFox Schiff

DC District Court Judge Rules Against CMS’s Site-Neutral Policy, Vacates CY 2019 Outpatient Prospective Payment System (OPPS)...

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On September 17, 2019, the US District Court for the District of Columbia ruled in American Hospital Association, et al. v. Alex Azar, II, et al that the Centers for Medicare & Medicaid Services (CMS) exceeded its statutory...more

McGuireWoods LLP

CMS’s Site-Neutrality Payment Cuts Lose in D.C. District Court

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On Sept. 17, 2019, a Washington, D.C. district court judge ruled that the Centers for Medicare & Medicaid Services (CMS) “exceeded its statutory authority when it cut the payment rate for clinic services at off-campus...more

King & Spalding

Victory for Hospitals as Judge Rules that CMS’s Reduction of Medicare Payments for Outpatient E&M Services Was Ultra Vires

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On September 17, 2019, U.S. District Judge Rosemary M. Collyer of the U.S. District Court for the District of Columbia awarded summary judgment in favor a group of more than 40 hospitals on their challenge to CMS’s decision...more

Brownstein Hyatt Farber Schreck

Court Vacates Rule That Lowered Medicare Payments to Off-Campus Clinics

Hospitals can breathe (at least temporarily) a sigh of relief as the U.S. District Court for the District of Columbia determined that the Centers for Medicare & Medicaid Services (CMS) exceeded its statutory authority when it...more

Foley & Lardner LLP

Site-Neutral Hospitals Find Reprieve for their Outpatient Departments Through the Courts

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On September 17, 2019, the D.C. District Court held that the Centers for Medicare & Medicaid Services (CMS) exceeded its statutory authority when it cut the payment rate for clinic services at off-campus provider-based...more

Sheppard Mullin Richter & Hampton LLP

D.C. District Court Vacates CMS Final Rule, Finds that CMS’ Lesser Reimbursement of Services Provided at Grandfathered Off-Campus...

On September 17, 2019, the U.S. District Court for the District of Columbia ruled against the Centers for Medicare and Medicaid Services (“CMS”), vacating CMS’ 2018 Final OPPS Rule, which cut Medicare reimbursement rates for...more

K&L Gates LLP

K&L Gates Triage: Activation of Validation Edits for OPPS Providers with Multiple Service Locations

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The Centers for Medicare and Medicaid Services (CMS), recently announced that it plans to activate systematic validation edits for Outpatient Prospective Payment System (OPPS) providers with multiple service locations that...more

Bricker Graydon LLP

CMS proposes payment cuts for hospital clinic visits in off-campus provider-based departments

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In its Hospital Outpatient Prospective Payment System (OPPS) proposed rule, released July 29, 2019, the Centers for Medicare and Medicaid Service (CMS) proposes to finalize a two-year phase-in of site-neutral payment cuts for...more

Verrill

Summer is Here, But Will Your Medicare Outpatient Claims Get Paid?

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Your hospital may have some corrective work to do over the next few weeks if you want to avoid delays in receiving payment for your Medicare claims for services rendered at off-campus outpatient provider-based departments....more

Bricker Graydon LLP

Hospitals with off-campus provider-based departments: Check your PECOS enrollment file

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Now is the time to double and triple check your Medicare Provider Enrollment, Chain, and Ownership System (PECOS) enrollment file to make sure all information for off-campus provider-based service locations is correct. ...more

Robinson+Cole Health Law Diagnosis

2019 Physician Fee Schedule Rule Review: Off-Campus Provider-Based Hospital Departments

On November 1, 2018, the Centers for Medicare & Medicaid Services (CMS) released a final rule (Rule), which includes modifications to Medicare payment policies and rates....more

Foley & Lardner LLP

Off-Campus Hospital Outpatient Departments Take Another Hit in CMS Final Rule

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On November 2, 2018, CMS released an on-line display copy of its Outpatient Prospective Payment System (OPPS) Final Rule implementing payment changes effective January 1, 2019. The official Federal Issuance is expected on...more

Holland & Knight LLP

CMS Releases the 2019 OPPS and ASC Payment System Final Rule

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• The Centers for Medicare & Medicaid Services (CMS) has issued the Calendar Year (CY) 2019 Final Rule that updates payment rates and policy changes in the Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory...more

K&L Gates LLP

CMS Issues CY 2019 OPPS Final Rule

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On November 2, 2018, the Centers for Medicare & Medicaid Services (“CMS”) issued in pre-publication format the final rule for the Medicare Hospital Outpatient Prospective Payment System (“OPPS”) and the Medicare Ambulatory...more

McGuireWoods LLP

CMS Proposes More Payment Cuts for Hospital Off-Campus Provider-Based Departments

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Since the passage of the Bipartisan Budget Act of 2015, certain off-campus provider-based departments (PBDs) have seen their payment rates cut by nearly 60 percent. Now, in its recently released calendar year (CY) 2019...more

Baker Donelson

CMS Proposes Major "Site-Neutral" Changes to Payments for Off-Campus Locations

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CMS recently published its proposed Medicare outpatient prospective payment system (OPPS) rule for calendar year (CY) 2019. The rule contains a number of "site-neutral" proposals that, if adopted, will result in lower...more

K&L Gates LLP

CMS Issues Proposed Medicare PFS Rule for CY 2019

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On July 27, 2018, the Medicare Physician Fee Schedule (PFS) Proposed Rule for Calendar Year (CY) 2019 (PFS Proposed Rule) was published in the Federal Register....more

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