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Regulatory Compliance: Off-Campus Provider-Based Hospital Outpatient Departments

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Regulatory Compliance: Off-Campus Provider-Based Hospital Outpatient Departments

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Murer Consultants Expert Advice: Regulatory Compliance

The Healthcare field is largely shaped and guided by state and federal regulation. Murer Consultants stays abreast of the latest developments in an ever-changing regulatory environment in service to a diverse client base across a broad range of regulatory issues.

With this is mind, Murer is compiling its top tips to assist you with compliance.

Tip #1: Off-Campus Provider-Based Hospital Outpatient Departments May Still Be Good Business

The Bipartisan Budget Act of 2015 impacted Medicare reimbursement for new off-campus provider-based hospital outpatient departments (“HOPDs”). However, these regulatory changes led some providers to conclude that the Act makes it impossible to develop new off-campus provider-based HOPDs. Not so.

Murer Recommends: New off-campus HOPDs may still be developed. They will have to use the PN modifier when submitting claims and they will be reimbursed 50 percent of the OPPS rate. However, such structuring may still be beneficial.

50 percent of the OPPS rate is oftentimes greater than the Medicare Physician Fee Schedule reimbursement for the practice expense component. Non-governmental payers may still reimburse at hospital rates. And finally, 340B program eligibility for new off-campus HOPDs remains intact.

Rather than assuming that new off-campus HOPDs are an impossibility, hospital providers must evaluate the scope of service intended at the remote site, the potential governmental and non-governmental payer reimbursement impacts of provider-based structuring, and the savings associated with 340B eligibility.

Murer Consultants is pleased to assist hospital providers with understanding provider-based requirements and the reimbursement variables associate with both existing and new provider-based facilities. Visit our Regulatory info center or speak with a consultant today by contacting Murer at 708.478.7030 or info@murer.com.

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