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Proposed Congressional Budget May Affect Off-Campus Provider-Based Locations

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Proposed Congressional Budget May Affect Off-Campus Provider-Based Locations

In the wee hours of Monday night, Congressional leaders and President Obama appear to have reached a tentative budget deal that may carry implications to treatment of off-campus provider-based outpatient departments. In a Discussion Draft of the proposed budget prepared for purposes of review, Congress proposed to amend Section 1883 of the Social Security Act.

The amendment outlines prospective changes to off-campus provider-based outpatient department Medicare reimbursement. Based on the language in the Discussion Draft, providers currently billing off-campus outpatient department services as hospital-based under the Medicare Outpatient Prospective Payment System (“OPPS”) are grandfathered and will not be affected by this change. Reimbursement for on-campus provider-based services (those within 250 yards of the hospital’s main building) also will remain unaffected.

Beginning January 1, 2017, off-campus hospital outpatient departments, which begin providing services after the date this legislation is enacted, would no longer qualify for payment under the OPPS. These facilities would solely be eligible for Medicare reimbursement from other applicable payments systems, such as the Ambulatory Surgical Center payment system or the Medicare Physician Fee Schedule (MPFS).

Importantly, as drafted, the proposed legislation has carved out emergency services provided in off-campus hospital-based locations.

It is also unclear at this time how this proposed legislation will impact 340B off-campus child sites.

As stated above, Congress prepared this Discussion Draft for purposes of review and has not yet enacted the proposed legislation. The proposed legislative language is unclear at this time, and refinements through enabling regulations will likely be needed to ascertain the full impact. Murer Consultants will continue to provide detailed updates as this the legislative process unfolds.

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