Q&A: CMS awareness of provider-based entities
Q. How does CMS become aware of the existence of provider-based entities? Do hospitals need to report this information to CMS?
A. Hospital leaders may naively believe that CMS has no definite method of ascertaining that the hospital is operating a specific provider-based department. However, there are several ways in which CMS may become aware that a hospital is operating a provider-based department.
Hospitals are required to submit annual cost reports that list the cost centers and departments operated by the hospital. CMS may become aware of a provider-based department’s existence by examining these cost reports, especially in instances where the department is housed in buildings outside of the main hospital, because the addresses of these departments may be disclosed on the cost report. Based on that disclosure, CMS may begin an audit of the use of that provider-based department for that cost-reporting period and all prior periods.
CMS may also become aware of provider-based departments through routine certification and recertification surveys, even those performed through deemed status accreditation agencies like The Joint Commission.
For more information, see Provider-Based Entities: A Guide to Regulatory and Billing Compliance, Second Edition.
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