News & Analysis as of

Off-Campus Departments

Will the Massachusetts Proposed Legislation on Hospital Outpatient Facility Fees Have a Nationwide Impact?

by Foley & Lardner LLP on

In some states, including the Commonwealth of Massachusetts, “site neutrality” for outpatient hospital reimbursement is factoring into state-specific health reform and cost containment initiatives. This potentially goes...more

CMS Proposes Substantial Payment Reductions in CY 2018 for Off-Campus Hospital Outpatient Departments Subject to the Site-Neutral...

by K&L Gates LLP on

On July 20 and 21, 2017, respectively, the Centers for Medicare & Medicaid Services (“CMS”) released a proposed rule addressing changes to the hospital Outpatient Prospective Payment System (“OPPS Proposed Rule”) and Medicare...more

New “Site Neutrality” Proposed Rule Would Slash Hospital Outpatient Payments for Off-Campus Services by 50%

by Seyfarth Shaw LLP on

In a proposed rule published in the Federal Register on July 21, 2017, the Centers for Medicare & Medicaid Services (“CMS”) moved to cut payments for most services provided by off-campus locations of hospitals by 50 percent. ...more

CMS Releases Proposed Rule for 2018 Physician Fee Schedule

by King & Spalding on

On July 13, 2017, CMS proposed a rule (Proposed Rule) updating payment policies and rates, as well as the quality provisions, for the Medicare Physician Fee Schedule (PFS). Among other provisions, the Proposed Rule reduces...more

2017 Brings Big Changes for Off-Campus Provider-Based Facilities

by Williams Mullen on

Historically, the Centers for Medicare and Medicaid Services (CMS) has reimbursed items and services furnished by provider-based departments (PBDs), both on and off campus, under the Medicare Hospital Outpatient Prospective...more

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

by Alston & Bird on

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...more

Mid-Build Provider-Based Department (PBD) Attestation Filing Deadline Fast Approaching (Checklist Included)

by Williams Mullen on

Providers seeking to classify certain off-campus departments as “mid-build” for purposes of eligibility for Hospital Outpatient Prospective Payment System (OPPS) reimbursement must file a provider-based attestation with their...more

Feb. 13 Deadline Looms for Provider-Based Departments Seeking Mid-Build Exception

by Polsinelli on

A new section of the 21st Century Cures Act provides much-needed relief for hospitals with an off-campus provider-based department (off-campus PBD) that was mid-build or under development as of November 2, 2015 (the Mid-Build...more

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

by Polsinelli on

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

21st Century Cures: A Closer Look

by McDermott Will & Emery on

On December 7, 2016, the US Congress enacted the 21st Century Cures Act, substantial legislation intended to accelerate “discovery, development and delivery” of medical therapies by encouraging biomedical research investment,...more

Reimbursement Changes for Hospital Off-Campus Provider-Based Departments

by McGuireWoods LLP on

Off-campus provider-based departments (PBDs) of hospitals face changes in reimbursement beginning Jan. 1, 2017, the effective date of the Centers for Medicare & Medicaid Services (CMS) outpatient prospective payment system...more

CMS Clarifies the Application Processes for the Mid-Build Exception under the 21st Century Cures Act and for Relocation Exception...

by King & Spalding on

CMS has issued guidance documents addressing how hospitals can (1) qualify an off-campus provider-based department (PBD) for the “mid-build” exception set forth in the 21st Century Cures Act and (2) request from their CMS...more

New billing modifier required for services furnished at certain off-campus provider-based departments on or after January 1, 2017

by Dentons on

Changes to Medicare billing and payment rules for services furnished at certain off-campus provider-based departments (PBDs) went into effect on January 1, 2017. Pursuant to the statutory “site-neutral” payment policy enacted...more

CMS Issues Time-Sensitive Instructions for Provider-Based Clinics That Have Relocated

by Morgan Lewis on

Hospitals that have relocated a provider-based clinic after the enactment of the Bipartisan Budget Act must take action now. Centers for Medicare & Medicaid Services (CMS) recently released guidance on extraordinary...more

The 21st Century Cures Act

by Baker Ober Health Law on

Signed into law by President Obama on December 13, 2016, the 21st Century Cures Act (Act) was overwhelmingly supported in both houses of Congress and comprises a dizzying array of provisions aimed to improve and modernize...more

21st Century Cures Act Provides Some Welcome Relief

by Foley & Lardner LLP on

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 Final Rule and 21st Century Cures Act Include Good and Bad News for Provider-Based Sites

by Baker Ober Health Law on

CMS recently published its final outpatient prospective payment system (OPPS) rule, which includes its new policies governing payment related to services furnished at off-campus provider-based departments (OPBDs). 81 Fed....more

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

by King & Spalding on

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

21st Century Cures Act to provide modest relief from site-neutral provider-based department payment policy

by Dentons on

The 21st Century Cures Act (H.R. 34) was recently overwhelmingly approved by both houses of Congress and reportedly will be signed into law by President Obama on December 13, 2016. Section 16001 of the Act modifies a...more

21st Century Cures: Congress Approves Legislation Expanding Hospital Site-Neutral Payment Exceptions and Making Other Payments...

by McDermott Will & Emery on

The 21st Century Cures Act encourages biomedical research investment and facilitates innovation review and approval processes, but also serves as a vehicle for a wide variety of other health-related measures, including...more

CMS Issues Final Rule on Off-Campus Hospital Department Reimbursement

by Williams Mullen on

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

The Wait is Over: CMS Delivers Post-BBA Provider-Based Policies in Final 2017 OPPS

by BakerHostetler on

Now that the rule is out, work to implement the BBA changes begins in earnest. CMS commemorated the one-year anniversary of the Bipartisan Budget Act of 2015 (BBA) with the traditional gift of paper, offering...more

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

by Stinson Leonard Street on

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 Announces Final Rule Implementing Site-Neutral Payment Rule for Certain Off-Campus Hospital Outpatient Provider-Based...

by K&L Gates LLP on

On November 1, 2016, the Centers for Medicare & Medicaid Service (“CMS”) released the pre-publication form of its much-anticipated Hospital Outpatient Prospective Payment System (“OPPS”) CY 2017 final rule with comment period...more

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