In response to a “growing trend toward hospital acquisition of physician offices and subsequent treatment of those locations as off-campus provider-based outpatient departments,” CMS proposes to begin collecting data that would allow the agency to analyze the frequency, type, and payment for services furnished in off-campus PBDs. CMS notes that in its March 2012 Report to Congress, MedPAC questioned the appropriateness of increased Medicare payment and beneficiary cost-sharing for provider-based physician practices, and has recommended that Medicare pay selected hospital outpatient services at the Medicare Physician Fee Schedule (MPFS) rates. CMS is considering creating a HCPCS modifier that could be reported with every code for services furnished in off-campus PBDs and/or requiring hospitals to itemize costs and charges for their PBDs as outpatient service cost centers on their Medicare cost reports. CMS invites comments on the best way of collecting this data. Hospitals that have more than one campus with inpatient beds may want to comment on this rule to obtain clarification from CMS regarding the definition of what is “off-campus” for purposes of the proposed new modifier.