The Centers for Medicare and Medicaid Services ("CMS") posted on its website the early release version of the calendar year 2008 proposed rule for the hospital outpatient prospective payment system and several other Medicare topics ("Proposed Rule") including several affecting critical access hospitals ("CAHs").
Included within the Proposed Rule is a proposal to significantly limit, if not effectively eliminate for many CAHs, the ability to create off campus provider (hospital) based locations after January 1, 2008. For this reason, you should consider providing comments to CMS explaining the importance of provider based clinics to your critical access hospital. Click here to read a summary prepared by the law firm Hall, Render, Killian, Heath & Lyman S.C.
If your organization is considering off-site provider based clinic implementation by 1-1-08 you should complete an analysis of the financial and operational impact of converting your off-site clinics to provider-based clinic status for Medicare.
Your Next Steps
Wipfli can assist with the impact analysis and/or implementation assistance as well as provide a PBC implementation service that can assist your organization in completing implementation of your clinics in 2007. The key components of the service include:
- Development of the implementation work plan.
- Establishment and oversight of the work team.
- Completion/review of the Medicare attestation statement.
- Timely submission of the attestation to CMS and the local intermediary.
- Verification of changes needed to accurately bill the UB04 and 1500 under the PBC program.
- Charge master revisions to set up PBC charging.
- Documentation of the changes for the Medicare cost report.
- Assistance with the other requirements of the PBC program.
If you have questions or would like additional information, please contact: