Big Changes and Uncertainty Looming for Off-Campus Provider-Based Departments

Alston & Bird
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Originally posted in Bloomberg BNA’s Medicare Report, 28 MCR 96, 2/3/17.

On November 1, 2016, the Centers for Medicare & Medicaid Services (CMS) released the Hospital Outpatient Prospective Payment System (HOPPS) - Final Rule with Comment and Final CY2017 Payment Rates ("Final Rule").

As part of the Final Rule, the agency implemented Section 603 of the Bipartisan Budget Act of 2015 (BBA), which establishes new limitations on "provider-based" reimbursement for certain off-campus provider-based departments (PBDs) under the HOPPS.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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