CMS Released FAQs Clarifying How to Relocate a Hospital Outpatient Department to the Patient’s Home

CMS recently published FAQs clarifying the process outlined in its Second Interim Final Rule for how hospitals can relocate a hospital outpatient department (“HOPD”) to patients’ homes or other addresses. The process was originally described in CMS’ Second Interim Final Rule published on April 30th to provide hospitals additional flexibility during the COVID-19 pandemic. The new FAQs provide clarity specifically on how a hospital should notify CMS of such relocation request and how to bill when relocating the HOPD. The request is retroactively applied to March 1st and must be submitted to the CMS Regional Office (“CMS RO”) within 120 days of billing from the new location. Advis summarized below the information needed to submit the relocation request to the CMS RO and use of modifiers for hospital billing considerations.

Temporary Extraordinary Circumstances Relocation Request Submission

For a hospital to relocate an HOPD, they must email the following information to the CMS RO:

  1. The hospital’s CCN;
  2. The date the hospital began to furnish services at the new location;
  3. The address of the original on-campus HOPD or excepted off-campus HOPD (or partially relocated HOPD, as applicable);
  4. The new address(es) of the relocated HOPD(s);
  5. A brief description of the justification for the relocation, the role of the:
    1. Relocation in the hospital’s operations in addressing COVID-19, and
    2. Why the new HOPD location is appropriate for furnishing covered outpatient items and services;
  6. An attestation that the relocation(s) is/are not inconsistent with the state’s emergency preparedness or pandemic plan; and
  7. A point of contact (name, title, telephone, email) at the hospital for the request.

Hospitals do not need to send a new email for each address the HOPD is relocating to during the PHE. Rather, hospitals can send an email request that includes all of the addresses the HOPD has relocated to over a period of weeks or months.  Hospitals should also notify the CMS RO of the addresses of any patients’ homes to which the HOPD is relocating if it is intended to be paid under the OPPS for these services.

Advis recommends creating a spreadsheet including all of the addresses the HOPD is relocating to and sending it as an attachment to the CMS RO with the other relocation request information in the body of the email. Advis is happy to assist providers with developing their request and submitting it to the CMS RO.

Billing Considerations for Relocated HOPDs

  1. In cases where the services are furnished via telecommunication technology, but are not telehealth services, the hospital should continue to bill as it ordinarily would using the appropriate modifiers and condition codes, as described below.
  2. Hospitals must continue billing for HOPD services using the PO and PN modifier.
    1. On-campus HOPD relocates to a patient’s home or other off-campus location under approved relocation request – PO modifier (paid under the OPPS, including the reduced rate for clinic visits at excepted off-campus HOPDs).
    2. Excepted off-campus HOPD (i.e., has an effective date before November 2, 2015) relocates to patient’s home or another off-campus location under approved relocation request – PO modifier (paid under the OPPS, including the reduced rate for clinic visits at excepted off-campus HOPDs).
    3. Non-excepted off-campus HOPDs – PN modifier (paid at PFS-equivalent rate).
    4. An HOPD whose request was denied, or that chose not to seek a relocation request/provide specific addresses to the CMS RO when rendering services to a patient at home – PN modifier (paid at PFS-equivalent rate).
  3. HOPDs that relocate and bill from a new address as a result of the Relocation Request must use the “CR” condition code with professional claims and “DR” condition code for institutional claims.
  4. Note: When a registered outpatient of the hospital is receiving a telehealth service, the hospital may bill the originating site facility fee (Q3014) to support such telehealth services furnished by a physician or practitioner who ordinarily practices there and bills for the telehealth service that is or would otherwise be furnished in the HOPD. This includes patients who are home, when the home is made provider-based to the hospital.

Published: June 25, 2020