Q&A: Provider-based status for buildings connected by a hallway

Q. If we have a building that is across the parking lot from the main building of the hospital and connected with a hallway, is that considered on-campus?

A. Although your regional office has the final word, this would appear to be on-campus. Your campus is measured from any point of the main buildings of the hospital to any point of the other building. If the building or department is within 250 yards, measured this way it would be considered on-campus. In this case, the building might be considered part of your main buildings by the regional office because of the connecting hallway. If not, they would determine if the closest part of the physical structure of the building is within 250 yards. Depending on the size of the parking lot it should be within 250 yards and therefore considered on-campus. If you are having difficulty determining the buildings and departments on your campus, you may consult your compliance office. Your compliance department, through their EMTALA compliance efforts, should have already determined exactly which departments are on- and off-campus and the same definition for determining on and off-campus applies to provider-based departments.

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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