Hospitals that seek to establish provider-based OPDs should complete their work soon.

A near-final discussion draft of a House budget bill, which the White House has apparently agreed to in principle, would end the provider-based status for hospital off-campus departments beginning January 1, 2017. Hospitals that already bill in a certain space under provider-based status will be grandfathered in if they do so prior to the legislation’s enactment date. Accordingly, providers that want to treat a space as provider-based but do not currently do so must convert that space quickly and begin billing for services provided there prior to the enactment date. Hospitals that already have provider-based clinics may want to verify compliance with the Provider-Based Rule to ensure that they do not permanently lose provider-based status. This legislation will also hugely affect the 340B Drug Pricing Program and providers that plan to bill under the program.