Recent Provider-Based Legislative Changes: Any GME Implications?

On November 2, 2015, President Obama signed into law the Bipartisan Budget Act of 2015, among other things, making changes to Medicare reimbursement for outpatient services furnished in off-campus provider-based departments (Off-Campus PBDs). (For more details about the new law's impact on Off-Campus PBDs, read Dentons' in-depth analysis about how the Bipartisan Budget Act materially impacts hospital outpatient services reimbursement.) Off-Campus PBDs that provided outpatient services as of November 2, 2015, will be "grandfathered" and will continue to be paid under Hospital Outpatient Prospective Payment System (OPPS) rates. Beginning January 1, 2017, however, any facility that begins billing as an Off-Campus PBD on or after November 2, 2015, will not receive OPPS rates but rather will be paid under the lower Medicare Physician Fee Schedule (MPFS) or ambulatory surgery center (ASC) rates, as applicable.