by Admin | November 3, 2016 11:10 am
November 3, 2016—A new federal rule that changes how Medicare pays for services at certain hospital off-campus departments likely won’t prevent hospitals from enrolling the sites in the 340B drug discount program[1] in 2017.
On Nov. 1, the Centers for Medicare and Medicaid Services published a final rule[2] implementing the site neutrality provision in Section 603 of the Bipartisan Budget Act of 2015. Hospitals have been concerned that CMS’s implementation could affect 340B because off-site clinics, departments, and services of a 340B hospital cannot register as 340B child sites to use 340B drugs unless they show outpatient costs and charges on a reimbursable line of the hospital’s Medicare cost report.
Under the proposed rule CMS published in July, hospitals would not have billed Medicare for services provided in a new off-campus provider-based departments (PBDs). That left open whether a new off-campus PBD would have costs and charges to report on a reimbursable line of the cost report. 340B Health, the association of hospitals and health systems in the 340B program, submitted comments[3] to CMS requesting that whatever payment system CMS adopted, hospitals be allowed to report costs and charges for new off-campus sites on that report.
In the final rule, CMS adopted a significantly different payment system for new off-campus PBDs than the one it proposed. Because the revised policy is so different, CMS issued it as an interim final rule effective Jan. 1, 2017 and is accepting comments until Dec. 31, 2016. Under the interim final rule, hospitals will bill Medicare for services provided in new off-campus PBDs on the institutional claim form using a new modifier to identify the services. Medicare will pay hospitals for those services under new, reduced rates (generally, 50 percent of the OPPS rate) that will apply specifically to new off-campus PBDs.
Although it appears hospitals will be able to list costs and charges associated with new off-campus PBDs on reimbursable lines of the cost report in 2017, CMS also stated that it “will make adjustments as necessary to the payment mechanisms and rates through rulemaking that could be effective in CY 2017.” CMS anticipates using the 2017 payment method for 2018 to give the agency time to create a long-term payment system for new off-campus PBDs based on claims data from those facilities, which CMS suggests could be implemented for 2019. The agency notes that such a long-term system could require hospitals to bill for off-campus PBD services using either the professional or institutional claim form.
Hospitals have expressed concern that billing on the professional claim form may make it harder for costs and charges to be listed on the cost report and may make cost reporting more complicated.
Source URL: https://340binformed.org/2016/11/cms-rule-likely-wont-block-hospitals-using-340b-in-new-offsite-locations/
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