CMS recently released the display copy of the OPPS/MPFS Final Rule for CY 2015 which finalizes proposals related to the reporting of services provided in hospital off-campus provider-based departments (“PBDs”).  The Final Rule can be found here.

The changes require hospitals to identify services provided in off-campus PBDs through use of a new HCPCS code modifier on the hospital claim (UB) and through use of new place of service (“POS”) codes on the professional claim (1500).  Mandatory reporting of the hospital modifier is delayed until January 1, 2016, but the new POS codes will be required as soon as they are available, which is not expected before July 1, 2015.

This data collection is a result of OIG Work Plan review items which continues to include a comparison of “Provider-Based” and “Freestanding Clinics” for 2015.  Further, CMS has increased its scrutiny of PBDs, resulting in several provider-based status denials over the last few years.  Such denials often result in recoupment and appeal activity.