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OPPS Final Rule Finalizes Limits for Off Campus Departments

First few Article Sentences

On November 1, 2016, the Centers for Medicare and Medicaid Services (CMS) issued the long-awaited implementation of the “site-neutrality” provisions of the H.R. 1314 Bipartisan Budget Act of 2015 (BiBA Section 603). The Final Rule will cause new (non-grandfathered, post 11/2/2015) hospital off-campus outpatient departments to no longer be reimbursed under the Medicare Outpatient Prospective Payment System (OPPS). Rather, those locations are deemed “nonexcepted” clinics and will receive something less than 50% of the old OPPS rate (at least initially) to approximate Medicare Physician Fee Schedule (MPFS) payment. In other words, the former financial advantage to locations holding provider-based status will largely disappear for new outpatient projects, with total payment (physician and technical component) approximating what would be paid for the service if performed in a free-standing physician office.

Vernaglia, Lawrence W.

Storey, Cheryl

Moss Adams LLP

CMS Site-Neutrality

November 7, 2016

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