Q&A: Provider-based department designation

Q. We have a provider-based department that was off-campus and it recently moved on-campus. Will it lose its provider-based designation?

A. No. The provider-based designation is a separate analysis and actually the on-campus requirements are easier to meet than the off-campus requirements. You should verify you still meet the requirements and ensure you have adjusted the address for the department on your 855 enrollment form. You may also opt to do an attestation, or amend the attestation originally filed for this department.

When the department was off-campus, it was grandfathered (or “excepted”) from application of the new payment methodology for off-campus departments, assuming it was operating prior to November 2, 2015. You may be concerned the department would lose its “excepted” status because of CMS guidance on relocation of grandfathered departments. That would not be the case here. Although the department did relocate, the new payment provision only affects off-campus departments. The department is now on-campus and therefore, would not be affected by the new payment provision because it is on-campus, even though it is no longer grandfathered.

Editor’s note: This question was answered by Kimberly Anderwood Hoy Baker, JD, CPC, director of Medicare and Compliance for HCPro, a division of BLR, in Middleton, Massachusetts.

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