Off-Campus Outpatient Departments Impacting Pulmonary Rehabilitation

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Sent Aug. 31, 2016

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A hospital outpatient department is considered “off-campus” if it is more than 250 yards from the main hospital campus. Section 603 of the Bipartisan Act of 2015 changed the way these departments are paid in an effort to slow the rate of physician practices being acquired by large hospital systems. Basically, physician services acquired by hospitals that had enjoyed being paid a higher rate under the Hospital Outpatient PPS rates are now paid under the Physician Fee Schedule, which amounts to less payment for the same services. An unintended consequence of the statutory change negatively impacts Medicare beneficiaries because the rule will inhibit expansion of pulmonary rehab services which are clearly beneficial to those suffering from Chronic Obstructive Pulmonary Disease. Data indicate that hospitals are clearly not purchasing these programs in order to receive higher payment. In comments to CMS, AARC and other pulmonary organizations recommended CMS make an exception to the rule for pulmonary rehab programs. Unfortunately, CMS has made it clear they do not have the ability to make changes because the language in the law is very clear. Options to amend the law are under consideration by the pulmonary groups.

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