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

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.

© Polsinelli PC, Polsinelli LLP in CaliforniaNational Law Review, Volume VII, Number 27

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About this Author

Shareholder

Colleen Faddick's practice includes advising clients regarding the structure of and relationships among health care providers and entities within the complex federal and state regulatory environment. Colleen focuses on Medicare and Medicaid reimbursement and enrollment issues and appeals, fraud and abuse and self-referral law issues, licensing and certification of health care entities, clinical trial compliance and agreements for sponsors and providers, medical device payment and manufacturer relationships with physicians. Colleen works with hospitals, large physician...

303.583.8201
Bragg E. Hemme, Polsinelli PC, Medical Licensure Lawyer, State Hospital Regulatory Attorney
Shareholder

In order to assist health care clients address their targeted business concerns, Bragg Hemme draws on a wealth of practical experience and a solid understanding of the industry gained during her time as both external and internal counsel. Her experience includes advising clients regarding the complex and ever-changing federal and state regulatory environment. She focuses her practice on government payer concerns such as:

  • Medicare, Medicare advantage and Medicaid reimbursement

  • Enrollment issues and appeals

  • Licensure and certification

  • Regulatory compliance

  • Fraud and abuse 

  • Self-referral law issues

303.583.8232
Sara Iams, Polsinelli Law Firm, Health Care Attorney
Associate

Sara Iams collaborates with clients and colleagues to navigate the complex health care regulatory environment. As a result, she helps clients achieve their desired business objectives.

Sara regularly counsels clients with respect to Medicare and Medicaid reimbursement matters, as well as general fraud and abuse issues. In doing so, Sara is not afraid to ask the difficult questions, and she pursues the answers with a steadfast attention to detail.

202-626-8361
Sarah Kocher, Polsinelli Law Firm, Healthcare Attorney
Associate

Sarah Kocher enjoys helping clients navigate the highly regulated field of health care. She works with health care providers and others across the industry on an array of compliance matters, including:

  • HIPAA

  • Health care fraud and abuse

  • Medical staff issues

  • Reimbursement

While in law school, Sarah was on the first place team in the 2012 National Transactional Health Law Competition and was...

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