CHA News Article

CMS Provides Timeline for Implementation of Section 603 of the Budget Act
HCPCS modifier FAQ issued for off-campus provider-based clinic services

The Centers for Medicare & Medicaid Services (CMS) announced today, during an open door forum, that it is targeting the calendar year (CY) 2017 outpatient prospective payment system (OPPS) rule for implementation of Section 603 of the Bipartisan Budget Act of 2015, which limits Medicare payment for new off-campus outpatient departments. CMS noted on the call that it is hearing from many providers around the country about various scenarios in which an off-campus provider-based clinic would be subject to the new payment policy. In response, CMS has set up an email address,, and encourages providers to use it to share those scenarios. While CMS will not likely respond, it will review the scenarios as part of the development of rulemaking on this policy.

CHA is also collecting this information and welcomes conversations with members to compile California-specific examples to provide to CMS next month. Members who wish to participate in the process should contact Alyssa Keefe at CHA will follow up in February with members who have already provided information.

In addition, CMS issued the attached frequently asked questions (FAQ) document about the requirement that an HCPCS modifier be reported with every code for outpatient hospital items and services furnished in an off-campus provider-based department of a hospital.

Established by the CY 2015 OPPS final rule, a two-digit modifier was added to the HCPCS annual file as of Jan. 1, 2015, with the label ‘‘PO.’’ While reporting the modifier was voluntary for CY 2015, it became mandatory beginning Jan. 1, 2016.

The CMS open door forum was recorded and is available for replay for two business days. To access the recording, dial (855) 859-2056 and enter conference ID 37127879.