In an era of increased compliance scrutiny and attention to government spending, hospitals are experiencing pushback on the concept of hospital outpatient departments (HOPDs) located outside the main hospital building. In the federal government’s vernacular, specifically The Centers for Medicare & Medicaid Services (CMS), these locations are referred to as “provider-based departments”. In Congress, there are at least four pending proposals that increase scrutiny on HOPDs and seek to further reduce reimbursement to hospitals. CMS has also increased compliance enforcement at these locations, through more scrutinous reviews during on-site surveys and/or compliance attestation reviews, as well as through enforcement of Medicare enrollment requirements and billing standards in the institutional claims process.

In this whitepaper, Advis will summarize: (1) pending Congressional legislation impacting HOPDs; (2) common compliance concerns with HOPDs; and (3) CMS enforcement trends with HOPDs. The purpose of this discussion is to stress the importance of fully comprehending your hospital’s utilization of HOPDs.

If not already done, it is now essential to create a completely accurate inventory of all of your HOPD locations, audit each location for compliance with applicable standards, and ensure enrollment and claims submissions are up to date. Hospitals may also consider evaluating the financial impacts of proposed reimbursement reductions under the Congressional proposals to best prepare for forthcoming change. Hospitals that fail to complete these steps will face increased likelihood of revenue losses associated with outpatient services.

Advis strongly recommends a full evaluation of your hospital’s provider-based compliance as soon as possible. Advis has decades of experience in navigating provider-based compliance for providers with CMS and the MACs, with hundreds of successful provider-based attestations completed across the country. Contact us today via our website here or by phone at (708) 478-7030.

Published: November 17, 2023