Provider-Based Reimbursement Reductions Input Wanted

In Section 603 of the Bipartisan Budget Act of 2015 (BBA), Medicare provider-based reimbursement changes eliminated hospital outpatient perspective payment system (OPPS) reimbursement as of January 1, 2017 for off-campus facilities that were not billed under the OPPS prior to November 2, 2015.¹

Many hospitals have off-campus outpatient services, which are defined by Medicare as taking place >250 yards from the main hospital campus.² Section 603 now states that any new provider-based hospital outpatient department is considered off-campus. This changes the reimbursement from a Prospective Payment System, or a fixed price for a given medical service based on a diagnostic code, to a regular Medicare Fee Schedule or, if applicable, the Medicare payment system for ambulatory surgical centers.

Feedback From Stakeholders

Congress passed the BBA Section 603 without input from providers and almost no notice to those that were building new off-campus departments. Stakeholders are advocating for changes to the BBA’s language because of the severity of changes in the act. As a result of the feedback, both positive and negative, received from providers, Congress is seeking formal input from stakeholders.¹
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Energy and Commerce Committee Chairman Fred Upton and Health Subcommittee Chairman Joseph Pitts issued a letter that solicits input “on policies that the Committee should examine in the context of both the enactment of [the BBA], as well as other changes to site neutral payment policies.”

The committee notes that feedback resulting in greater beneficiary or Medicare spending should include suggestions to neutralize the budget or result in savings for the Medicare program, showing that Congress has a clear goal to reduce overall Medicare spending. This is the time to encourage change for the BBA that results in a reasonable compromise for all involved parties.

Stakeholders are encouraged to submit feedback to provider-baseddepartment@cms.hhs.gov as soon as possible. Potential topics include clarification on the applicability of the BBA to sites under development as well as the impact of changes of ownership, relocations, site expansions, service changes, etc. on grandfathered sites.—Kelsey Moroz

References

1. Congress, CMS Seek Input on Provider-Based Reimbursement Reductions. The National Law Review. https://www.natlawreview.com/article/congress-cms-seek-input-provider-based-reimbursement-reductions. Accessed February 28, 2016.
2. Winfree P, Boccia R, Johnson JT, et al.  Analysis of the Bipartisan Budget Act of 2015. https://www.heritage.org/research/reports/2015/10/analysis-of-the-bipartisan-budget-act-of-2015. Accessed February 28, 2016.
3. https://www.stinson.com/Resources/Alerts/2015_Alerts/Reimbursement_Change_for_Off-Campus_Provider-Based_Clinics,_Physician_Offices,_and_Ambulatory_Surgical_Centers.aspx