2019 Physician Fee Schedule Rule Review: Off-Campus Provider-Based Hospital Departments

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On November 1, 2018, the Centers for Medicare & Medicaid Services (CMS) released a final rule (Rule), which includes modifications to Medicare payment policies and rates.

One area that is discussed in the rule is with regards to the payment of certain items and services when provided by certain off campus provider based hospital departments. As per Section 603 of the Bipartisan Budget Act of 2015, certain items and services, when provided by certain off-campus provider-based hospital departments, are not to be paid under the Hospital Outpatient Prospective Payment System (OPPS) as same are not considered covered outpatient department services under OPPS for payment purposes. In lieu of OPPS, CMS established in calendar year 2017 that the Medicare Physician Fee Schedule (PFS) would be the payment system for most of these items and services when furnished by certain off-campus provider-based hospital departments. Under the PFS, these items and services being furnished by these certain off-campus provider-based hospital departments are paid using a PFS Relativity Adjuster. In the Rule, CMS has made the PFS Relativity Adjuster for calendar year 2019 match the amount from calendar year 2018, which was 40 percent of the OPPS payment rate.

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