New FAQs address provider-based department billing, relocation requests

CMS clarified billing instructions for off-campus hospital outpatient services and provider-based departments (PBD) in its most recent update to its novel coronavirus billing FAQs.

The new FAQS are in Section G. Hospital Outpatient—Locations off of Hospital Campus. Topics addressed include:

• Temporary policy changes for relocated excepted and non-excepted PBDs. During the public health emergency (PHE), CMS is expanding the extraordinary circumstances relocation exception policy to include on-campus and excepted off-campus PBDs that relocate entirely or partially to new off-campus locations such as a temporary expansion location. A temporary expansion location may include a patient’s home. PBDs are able to being providing and billing for services at the new location using modifier -PO immediately while the regional office is reviewing the exception request and the exception request process itself has been streamlined. If the request is denied, the hospital must bill for services provided by that PBD using modifier -PN. Non-excepted PBDs are not eligible for an extraordinary circumstances relation request.
• Relocating PBDs without applying for an extraordinary circumstances relocation request. If a hospital chooses not to apply for a relocation request, it must bill for non-excepted services provided at the new location, including a patient’s home, at the non-excepted physician fee schedule equivalent rate. These services should be billed with modifier -PN.
• Relocating an excepted PBD to several locations. As part of the extraordinary relocation request application, a hospital must notify the regional office of the address or addresses to which its PBD is relocating within 120 days of the relocation. However, the hospital does not need to send a separate email for every relocation site. Instead, the hospital can send a single email that contains all of the addresses to which its PBD has relocated over a period of weeks.
  When a PBD is relocated to several patients’ home, the hospital must include the address of each patients’ home. However, the hospital should not include unnecessary personally identifiable information, such as diagnoses or names, in the request. The relocation request should be encrypted before it is emailed to further protect patients’ privacy.
• Relocating an excepted PBD to a patient’s home. If a hospital relocated a PBD to a patient’s home during the PHE and then must relocate a PBD to the same patient’s home again, it does not need to submit a second relocation request.
  If two different PBDs are relocated to one patient’s home, the hospital must submit requests for each PBD. Both requests could be included in the same email.
• Permanently relocating an excepted PBD. If a hospital relocates an excepted PBD during the PHE and then chooses not to move it back to its original location, the PBD will no longer be considered excepted after the PHE ends. The PBD would then be considered a new, non-excepted PBD and would bill using modifier -PN.

Hospitals should notify compliance, billing, and other affected revenue cycle staff of the new FAQs.