Description:-

Hospitals are increasingly establishing provider-based clinics of all types.  The provider-based rule (PBR) is complex, and there are definite ambiguities.  While hospitals can enjoy increased revenues from provider-based clinics, compliance with all the rules and regulations is challenging.  Recent changes in the supervisory requirements for provider-based operations have created confusion and new compliance challenges.

Additionally, with Section 603 of the Bipartisan Budget Act of 2015, there is the movement to change the rules and regulations relative to reimbursement for provider-based clinics.  In this workshop, the overall purpose and function of the provider-based rule is addressed as well as critical information concerning physician supervisory changes along with a discussion of the future of provider-based clinics.  Particular attention is made to rule changes as implemented by CMS relative to Section 603 of BBA 2015 and further changes made by Section 16001 of the 21st Century Cures Act.  Update information from the CY2018 and CY2019 OPPS and MPFS update Federal Registers will be discussed.

Teleconference/Webinar Objectives:- 

• To briefly review the Provider-Based Rule (PBR).
• To review the criteria that must be achieved for clinics to be recognized as provider-based.
• To update the current status of changes in payment to off-campus provider-based clinics as provided through Section 603 of the BBA 2015.
• To review the further changes made by the 21st Century Cures Act.
• To briefly update critical physician supervisory rule changes.
• To discuss documentation requirements relative to physician supervision requirements.
• To appreciate the increase in reimbursement for provider-based clinics.
• To understand the attestation and request for determination processes.
• To understand the need for updating and the documentation of organizational structuring relative to the PBR.
• To understand the review/audit process for assessing current and/or potential provider-based situations.
• To understand the economic benefits versus the compliance requirements.
• To appreciate the relationship of PBR relative to the Conditions for Payment, Conditions of Participation and gaining billing privileges.
• To understand the regulatory pressures for reducing reimbursement for provider-based clinics.
• To appreciate the evolving guidance that is being provided by CMS and the Regional Offices.
• To work through several case studies.

Teleconference/Webinar Outline/Agenda:-

• Review of the Provider-Based Rule (PBR)
  • Development of the PBR
  • 42 CFR §413.65
  • Review of Definitions
  • Rules and Regulations
  • Recognition by Non-Medicare Third-Party Payers
  • Very Brief History of Provider-Based Clinics
• Economic Advantages of Provider-Based Status
  • Clinics
  • Clinical Services
  • Costs for Provider-Based Status
• Current Activity Surrounding Medicare Payment for Provider-Based Clinics
  • OIG Recommendations
  • MedPAC Recommendations
  • CMS Data Gathering of Cost for Off-Campus Provider-Based Clinics/Operations
    • PO Modifier – UB-04
    • POS 19/22 Indicators - 1500
• • Section 603, BBA 2015 Changes Starting January 1, 2017
    • Final Rules for 2017
    • Payment Processor Non-Excepted Clinics
    • Special Issues
  • Section 16001, 21st Century Cures Act
    • Definition of ‘New’ Relative to BBA 2015
    • Mid-Build Exception for Grandfathering
  • CY2018 & CY2019 OPPS Federal Register – Policy Changes
  • CY2018 & CY2019 MPFS Federal Register – Payment Processes
• Provider-Based Requirements – Special Issues
  • Signage and Recognition
  • EMTALA Interface
  • Notice of Two Copayments
  • Split-Billing
  • Shared Space Concerns
  • Co-Location Issues
  • Under Arrangements
  • Other Regional Office Issues
• Physician Supervisory Requirements
  • Recent Changes and Clarifications
  • Relationship to Physician Incident-To Billing
• Provider-Based Audits
  • Process
  • Data Gathering and Assessment
  • Attestations and Requests for Determination
  • Action Steps
• Provider-Based Clinics – The Future
• Case Studies – Provider-Based Clinics

Prerequisites for Participating:- 

General knowledge of hospitals and various clinic and clinical operations.

Suggested Attendees:- 

All personnel involved with the provider-based clinic and clinical operations, compliance personnel, coding and billing personnel, nursing staff and interested physicians are encouraged to attend.