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

Polsinelli
Contact

Polsinelli

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 services furnished in off-campus provider-based departments (referred to as "off-campus PBDs") developed on or after November 2, 2015. 

Off-campus PBDs developed prior to November 2, 2015 are excepted from the Final Rule, but relocation of those otherwise excepted off-campus PBDs will generally compromise their excepted status. There is some limited leeway in the Final Rule that permits relocation due to extraordinary circumstances beyond the provider's control. In the Final Rule, CMS noted that it would issue sub-regulatory guidance on the technical process to submit a request for a relocation exception. That sub-regulatory guidance came on December 30, 2016. Key elements include:

  • For relocations that occurred between 11.2.15 and 12.31.16, submit a relocation request by 1.31.2017. If approved, the approval will be effective January 1, 2017.
  • Use CMS's suggested request form, available on pages 5-6 of CMS's relocation guidance.
  • Email submission is encouraged and the Regional Office contact information is included in the guidance document.
  • Email submission is encouraged and the Regional Office contact information is included in the guidance document.
  • Relocations after Jan. 1, 2017 must be submitted within 30 days following the extraordinary circumstance. If approved, the approval will be effective on the later of the date of relocation or date of relocation request.
  • Must use PN modifier until written approval from RO received. Once approval received, contact applicable Medicare Administrative Contractor for rebilling instructions.

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.

© Polsinelli | Attorney Advertising

Written by:

Polsinelli
Contact
more
less

Polsinelli on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide
- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.