Hospitals that have relocated a provider-based clinic after the enactment of the Bipartisan Budget Act must take action now.

Centers for Medicare & Medicaid Services (CMS) recently released guidance on extraordinary circumstance relocation exceptions for off-campus provider-based departments. This guidance provides information on how hospitals can request a relocation exception for an excepted off-campus department of a provider due to an extraordinary circumstance. The guidance gives mandatory instructions about what documentation must be sent, and to whom.

Most importantly, the guidance also states when that documentation must be sent. For an off-campus department of a provider that relocated due to an extraordinary circumstance between November 2, 2015 and December 31, 2016, hospitals must submit a written relocation exception request with supporting documentation by email to their CMS Regional Office no later than January 31, 2017.

For a relocation occurring on January 1, 2017 or later, hospitals must submit a relocation exception request no later than 30 days after the extraordinary circumstance occurred. The applicable CMS Regional Office will review relocation exception requests on a rolling basis for relocations that occur on or after January 1, 2017.