Hospitals are ever 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.
Format : LIVE WEBINAR Presenter : Duane C. Abbey, PhD Event Date : 02/28/2019 Time: 1 pm ET | 12 pm CT | 11 am MT | 10 am PT
Hospitals are ever 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.
Session 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/or the Regional Offices.
To work through several case studies.
Session Agenda:
Review of the Provider-Based Rule (PBR)
Economic Advantages of Provider-Based Status
Current Activity Surrounding Medicare Payment for Provider-Based Clinics
Provider-Based Requirements – Special Issues
Physician Supervisory Requirements
Provider-Based Audits
Provider-Based Clinics – The Future
Case Studies – Provider Based Clinics
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
Clinics
Clinical Services
Costs for Provider-Based Status
OIG Recommendations
MedPAC Recommendations
CMS Data Gathering of Cost for Off-Campus Provider-Based Clinics/Operations
Section 603, BBA 2015 Changes Starting January 1, 2017
Section 16001, 21st Century Cures Act
CY2018 & CY2019 OPPS Federal Register – Policy Changes
CY2018 & CY2019 MPFS Federal Register – Payment Processes
PO Modifier – UB-04
POS 19/22 Indicators – 1500CY2018 & CY2019 OPPS Federal Register – Policy Change
Final Rules for 2017
Payment Process or Non-Excepted Clinics
Definition of ‘New’ Relative to BBA 2015
Mid-Build Exception for Grandfathering
Signage and Recognition
EMTALA Interface
Notice of Two Copayments
Split-Billing
Shared Space Concerns
Co-Location Issues
Under Arrangements
Other Regional Office Issues
Recent Changes and Clarifications
Relationship to Physician Incident-To Billing
Process
Data Gathering and Assessment
Attestations and Requests for Determination
Action Steps
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