CMS IMPLEMENTATION UPDATE – Section 603 of Bipartisan Balanced Budget Act of 2015

We will provide an update on the July 6, 2016 Centers for Medicare and Medicaid Services’ (CMS) implementation of Section 603 of the Bipartisan Balanced Budget Act of 2015, which eliminates hospital-level OPPS reimbursement for all new (non-grandfathered) off-campus outpatient departments of hospitals that are not dedicated emergency departments (OCODP).

This significant, yet brief, statutory provision is already in effect. However, there are many unanswered questions, which we hope to address and clarify. These include:

• The impact of a change of services, site, or location for a grandfathered OCODP 


• Any impact to 340b drug pricing 


• The definition of “on campus” 


• Instances of change in ownership of grandfathered OCODPs 


• Treatment of expansion of space/services in a grandfathered OCODP

Foley and Moss Adams have been monitoring the development of CMS policy surrounding Section 603 since it was signed into law in November 2015, and we expect that the first formal guidance from CMS will be issued in connection with the CY 2017 OPPS/ASC Proposed Rule. While the publication date has not yet been established, the 2016 Proposed Rule was originally published in the Federal Register on July 8, 2015. In anticipation of a similar publication schedule for the CY 2017 Proposed Rule, we will cover any updates in early July 2016.

Presenters

Lawrence Vernaglia, Partner and Chair, Health Care Industry Team, Foley & Lardner LLP
Cheryl Storey, CPA , Partner, Moss Adams Health Care Industry Group, Moss Adams LLP
Jennifer Walsh, Government Affairs Director, Foley & Lardner LLP

There is no cost to participate in this program, but pre-registration is required. To participate, please use the Register Today button above or below. Instructions for accessing the program will be included in the registration confirmation email.

If you have questions or would like more information, please contact Michaella Johnson, Marketing Manager at Moss Adams, at 503.478.2289.