Q&A: Hospital facilities excluded from provider-based requirements

Q. Our hospital is located in a rural location where it is difficult to find specialty physicians to provide services to its hospital outpatients. Which of the following facilities that furnish services on or near the hospital campus would be excluded from provider-based requirements?

• A Medicare-certified HHA owned by the hospital with staff employed by the hospital
• Internal medicine, surgery, and pediatric clinics operated by the hospital in a hospital-owned building on the main hospital campus. The clinics are staffed by hospital employees, and the patients treated in the clinics are registered and billed as hospital outpatients.
• A nephrology clinic located five miles from the hospital campus that is owned by the hospital. The patients treated in the off-campus nephrology clinic are registered and billed as physician office patients. The nephrologists from the off-campus nephrology clinic have hospital medical staff privileges.

A. The hospital-owned and -operated HHA would be excluded from provider-based requirements. The HHA is separately certified by Medicare and, therefore, the patients treated by the HHA are admitted to the HHA and billed separately as HHA patients under the name and provider number of the HHA. The HHA must meet the HHA CoPs. Therefore, this separately certified entity is not subject to the provider-based requirements.

The off-campus hospital-owned nephrology clinic would also be excluded. Even though it is owned by the hospital, it is operated as a freestanding physician office clinic. Therefore, it is not a provider-based department.

For more information, see Provider-Based Entities: A Guide to Regulatory and Billing Compliance, Second Edition.

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