OPPS

News & Analysis as of

Jan. 31 Deadline: Off-Campus Provider-Based Relocations Requests

For relocations that occurred between 11.2.15 and 12.31.16, providers must submit relocation requests by 1.31.2017. The CY 2017 OPPS Final Rule brought significant changes to the way Medicare reimburses hospitals for...more

2016 – Health Law Year in Review

We are pleased to present our annual review of developments in the field of health law. The year was marked by key changes in False Claims Act jurisprudence and Medicare payment policy. 2016 also brought with it focused...more

CMS Corrects Final 2017 OPPS/ASC Rule, Results in Slight Payment Increase

CMS has published a notice correcting technical errors in its November 14, 2016 final rule with comment period updating the Medicare hospital outpatient prospective payment system (OPPS) and ambulatory surgical center payment...more

21st Century Cures Act Provides Some Welcome Relief

The 21st Century Cures Act (the “Cures Act”) (Pub. L. No. 114-255), which was signed into law by President Obama on December 13, 2016, includes a number of important health care provisions, and several address the...more

CMS Reminds Providers to Identify Off-Campus Provider-Based Departments on Enrollment Forms

In connection with CMS’s implementation of Section 603 of the Bipartisan Budget Act of 2015 (BBA15), which directs CMS to no longer pay hospitals the full OPPS rate for services furnished in non-excepted off-campus...more

CMS Issues Final Rule on Off-Campus Hospital Department Reimbursement

As of January 1, 2017, hospitals will receive lower Medicare reimbursement for items and services provided at certain off-campus provider-based facilities. This Alert provides an overview of the new reimbursement framework...more

OPPS Provider-Based Final Rule — A More Practical Approach From CMS

CMS recently finalized sweeping changes to the way Medicare pays hospitals for services furnished in “new” off-campus provider-based departments (referred to as “off-campus PBDs”). CMS revealed the changes on November 1...more

CMS Releases the 2016 OPPS Final Rule

On November 1, 2016, CMS published its final policy changes, quality provisions, and payment rates for 2017, as they relate to the Medicare Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center...more

Meaningful Use Changes in 2017 OPPS Final Rule

On November 14, 2016, the Centers for Medicare and Medicaid Services (CMS) published the 2017 Outpatient Prospective Payment System (OPPS) final rule in the Federal Register. The rule finalizes changes to the Electronic...more

2017 OPPS Final Rule: Payment to Off-Campus Provider-Based Departments

On November 1, 2016, the Centers for Medicare & Medicaid Services (CMS) issued the 2017 Medicare Outpatient Prospective Payment System (OPPS) Final Rule. One aspect of this rule is the implementation of payment decreases for...more

CMS Releases OPPS and ASC Payment Final Rules, Finalizes Changes to Off-Campus Provider-Based Status

On November 1, 2016, CMS released the final payment rates and policy changes in the Hospital Outpatient Prospective Payment System (OPPS) final rule (OPPS Final Rule) and Ambulatory Surgical Center Payment System Final Rule...more

CMS Finalizes Policies on Off-Campus Provider-Based Status CMS Will Pay Non-Excepted PBDs in 2017, But Adopts Nearly All Other...

On November 1, 2016, the Centers for Medicare & Medicaid Services (CMS) issued its CY 2017 Outpatient Prospective Payment System (OPPS) Final Rule, which includes the agency’s final policies implementing legislative changes...more

Compliance Concerns Raised Over Proposed Hospital Outpatient Department Rule

In an August 26, 2016, letter to the Centers for Medicare & Medicaid Services (CMS), the American Hospital Association (AHA) expressed serious concern over the portion of the calendar year 2017 hospital outpatient prospective...more

CMS Proposes OPPS Reimbursement Adjustments: What Hospital Outpatient Providers Need to Know

In early July, the Centers for Medicare & Medicaid Services (CMS) proposed Hospital Outpatient Prospective Payment System (OPPS) reimbursement rule changes that will impact reimbursement payment amounts and requirements for...more

Proposed 2017 Hospital OPPS Rule Would End Medicare Payments to Many Off Campus Facilities at the Same Levels as Hospital-Based...

Published on July 14, 2016, CMS’s proposed 2017 Hospital Outpatient Prospective Payment System (OPPS) rule calls for site-neutral payments that would stop Medicare payments to many off-campus facilities at the same level as...more

Also In The News - Health Headlines - August 2016

CMS Provides Update Regarding Patient Status Review Delay – On July 27, 2016 CMS posted an update regarding Quality Improvement Organization (QIO) reviews of patient status claims, which are currently paused. CMS notes that...more

CMS Proposes CY 2017 Home Health PPS Rate, Updates to ValueBased Purchasing Model and Quality Reporting

The US Department of Health and Human Services (HHS) Centers for Medicare & Medicaid Services (CMS) released proposed updates to its Calendar Year (CY) 2017 Home Health Prospective Payment System (HH PPS) in the July 5, 2016,...more

CMS Releases the 2016 OPPS Proposed Rule

On July 15, CMS published its proposed policy changes, quality provisions, and payment rates for 2017 as they relate to the Medicare Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC)...more

Provider-Based Status Post-BBA: CMS Offers Limited Answers, Requests More Feedback

For those in the hospital industry hoping for additional clarity regarding the operation and billing of provider-based departments (PBDs), the CY 2017 Outpatient Prospective Payment System (OPPS) Proposed Rule provides some...more

CMS Releases Details on Site-Neutral Payment Provision under Bipartisan Budget Act

On July 6, the Centers for Medicare and Medicaid Services (“CMS”) released the Medicare hospital outpatient prospective payment system (“OPPS”) and the Medicare ambulatory surgical center (“ASC”) payment system proposed rule...more

CMS Proposes Update to Medicare OPPS, ASC Rates and Policies for 2017

CMS has published its proposed rule to update the Medicare Hospital Outpatient Prospective Payment System (OPPS) and the Ambulatory Surgical Center (ASC) Payment System rates and policies for CY 2017. CMS proposes a 1.55%...more

CMS Releases Calendar Year 2017 OPPS Proposed Rule

On July 6, 2016, CMS released the Calendar Year (CY) 2017 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System Proposed Rule. In addition to significant proposals...more

CMS Issues Proposed Rule Addressing Off-Campus Outpatient Departments

The Centers for Medicare and Medicaid Services (CMS) published its 2017 Medicare Outpatient Prospective Payment System (OPPS) proposed rule on July 14, 2016 (the Proposed Rule). In part, the Proposed Rule addresses CMS’s...more

CMS Releases Proposed Outpatient Payment System Rule for 2017, Leaving Hospitals Unhappy

Last week, the Centers for Medicare and Medicaid Services (CMS) released its proposed rule for the Hospital Outpatient Prospective Payment System (OPPS) and the Ambulatory Surgical Center (ASC) Payment System for 2017. CMS...more

“Site Neutrality” for Off-Campus Outpatient Departments: Proposed Rule is Worse than You Expected!

CMS issued its Outpatient Prospective Payment System (“OPPS”) Proposed Rule for 2017 (the “Proposed Rule”) on July 6, 2016. The Proposed Rule will be published in the Federal Register on July 14, 2016. One highly-anticipated...more

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