Guidance expected to address when a provider-based location shares space with a clinic or another hospital. At the American Health Lawyers Association Medicare and Medicaid conference in March, David Wright, acting deputy director for the Center for Clinical Standards and Quality from the Centers for Medicare & Medicaid Services (CMS)…
Expect more changes to come for provider-based clinics. There has been much federal oversight activity regarding provider-based clinics of late. For those of you that have such clinics and/or are anticipating the development of such clinics, study the rules, regulations, and pronouncements of the Centers for Medicare & Medicaid Services…
Provider-based facilities may share space with a freestanding entity. Any provider that has an arrangement under which there is a freestanding clinic in a building that also contains provider-based or hospital space needs to understand both the relevant Centers for Medicare & Medicaid Services (CMS) policy and the law related…
Since the December 2015 passage of Section 603 of the Bipartisan Budget Act of 2015, dealing with new, off-campus, provider-based clinics/operations has become challenging. The basic idea of Section 603 is that these new off-campus clinics should be paid at a site-neutral level, which involves the Medicare Physician Fee Schedule…