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January 2017

  

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

  

 
 

  

     

  

 
 

For more information about this e-Alert, please contact:

  

Colleen M. Faddick

303.583.8201

Email | Bio

  

Bragg E. Hemme

303.583.8232

Email | Bio

  

Sara V. Iams

202.626.8361

Email | Bio

  

Sarah R. Kocher

202.777.8930

Email | Bio

  

To learn more about our Health Care practice, to contact one of our Health Care attorneys, or for more Health Care Intelligence, click here.

  

  


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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.

Please contact Polsinelli if you have questions about relocation, including what qualifies as an extraordinary circumstance that may warrant relocation.

For More Information

If you have questions regarding this alert, please contact one of the authors, a member of Polsinelli's Health Care Practice, or your Polsinelli attorney.

 
             

 

  

     

  

 
 

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