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GOOD NEWS — Murer Receives Guidance from CMS on Expanding Physical Space in Grandfathered HOPDs

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GOOD NEWS — Murer Receives Guidance from CMS on Expanding Physical Space in Grandfathered HOPDs

Murer continues to monitor legislative developments related to the CMS final OPPS rule issued on November 1, 2016, which contains provisions intended to implement “site neutral” reimbursement for certain off-campus provider-based locations.

CMS’ proposed rule issued in July 2016 appeared to take a strong stance against the expansion of the physical space for “grandfathered” off-campus HOPDs; yet the final rule was not as clear on this matter.  Murer therefore contacted the CMS Division of Outpatient Care directly for clarification.

Murer received CMS guidance stating a “grandfathered” off-campus HOPD may expand its footprint so long as it retains the same physical address that is listed on the Medicare 855A enrollment record as of November 2, 2015.  In other words, so long as the street address does not change, a “grandfathered” off-campus HOPD may expand existing physical space and continue to bill under the OPPS.

For example, a hospital outpatient center with three floors could add a fourth floor, and bill services under the traditional hospital method at OPPS rates from this fourth floor.  The key factor is ensuring the physical address for the HOPD is not altered and continues to match the address reported on the Medicare 855A enrollment record as of November 2, 2015.

Murer Consultants specializes in feasibility and development, and is available to assist you in designing strategies to expand existing footprints for “grandfathered” HOPDs in compliance with this CMS directive.  Should you have any questions regarding this information, or would like to discuss possibilities for expansion, please contact Murer at (708) 478-7030.

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