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.
To view the full alert, including key elements, click here
To learn more about Polsinelli's Health Care
practice, click here