The Sunset of Off-Campus Provider-Based Locations: What the Statute Says, Areas of Ambiguity and Practical Advice

March 17, 2016
American Health Lawyers Association
Webinar

Bass, Berry & Sims attorney Danielle Sloane will co-present during a webinar hosted by the American Health Lawyers Association on the topic of “The Sunset of Off-Campus Provider-Based Locations: What the Statute Says, Areas of Ambiguity and Practical Advice.” The webinar will discuss the neutral payment statutory provision eliminating outpatient reimbursement to most new off-campus outpatient facilities, and will:

  • Explain what the statute says and does not say
  • Address the areas of ambiguity under the statute, including the parameters for “grandfathering” existing provider-based facilities
  • Discuss implications for other programs and payers including the 340B program
  • Draw upon CMS’ current policy and practices to discuss some of the ways CMS may implement the ambiguous statutory provisions
  • Provide practical advice for how to manage the ambiguities today and for “hedging” against worse case scenarios
  • Discuss CMS’s increasingly strict enforcement of existing provider-based requirements and consider the implications of those actions for the future of the provider-based status

The webinar will take place Thursday, March 17 from 2:00 p.m – 3:30 p.m. Eastern Time.