Site-Neutral Billing Exemptions

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The Balanced Budget Bill Act of 2015 has a site-neutral billing provision relating to off-campus hospital outpatient departments (HOPDs).   Those are facilities away from the hospital campus but certified as part of the hospital and therefore qualified to receive a facility fee, like the hospital itself.  Medicare’s complaint was that hospitals were acquiring physician offices, certifying them as HOPDs, and then receiving significantly higher reimbursement—for the same service, by the same professionals, in the same facility.

The BBA had a simple resolution: the reimbursement would be the same whether the office was certified as an HOPD or not.  That would take care of new HOPDs.  And existing HOPDs were grandfathered.

But that left out what the House Ways & Means Committee calls “mid-build” facilities: those in the process of being built.  Bipartisan H.R. 2016 would grandfather those mid-build facilities, like existing HOPDs.

The bill would also exempt cancer hospitals from the site-neutral billing rule.

The name of the bill is The Helping Hospitals Improve Patient Care Act of 2016.  It’s noteworthy among Medicare-related bills for not having a snappy acronym.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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