Business Briefs: How Does Medicare Decide If Your HOPD is Provider-Based?

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Last month’s Business Briefs topic about provider-based hospital outpatient departments (HOPDs) generated many interesting questions from readers, including: 

• “As a nurse-run ostomy and wound care HOPD, are we provider-based?”
• “Our physician specializes in wound care, and we call our practice a ‘wound care clinic.’ Are we provider-based”?
• “I work in a hospital-affiliated wound care practice that is not on the hospital campus. Are we provider-based?”
• “We have been providing wound care in a rehabilitation department for many years. Are we provider-based?”
• “Some of my peers in other outpatient wound care departments told me their hospital submitted a provider-based attestation to Medicare. What is an attestation?”
• “How does Medicare decide if our outpatient wound care department is provider-based?”

The Centers for Medicare & Medicaid Services (CMS) and Medicare Administrative Contractors (MACs) have published lengthy regulations pertaining to provider-based HOPDs and make these regulations very accessible on their respective websites. Recently, one MAC published a checklist that is used to verify whether or not an outpatient department qualifies for provider-based designation. See the Table (to access, download the PDF version of this article by clicking the icon above) for the main portion of that checklist. The checklist can also be used to determine whether or not one’s department meets these qualifications. While reviewing the checklist, notice that it refers to a provider-based attestation. If your hospital administrators would like to submit a provider-based attestation, they should check with the MAC to determine whether or not they have any special requirements or a sample attestation form. Readers can access a sample attestation form by clicking here. (For those reading this article after July 2016, access the form in our online archives.)

After reading one MAC’s provider-based designation checklist and the sample attestation format, you’ll have a good idea as to whether or not your facility is a provider-based outpatient department. If you have any uncertainty, check with your hospital administration.

Kathleen D. Schaum & Associates Inc., Lake Worth, FL; and director, medical products, reimbursement, biotherapeutics at Smith & Nephew.    

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