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CMS Details Exceptions Process for Relocation of Off-Campus Departments

In new guidance, the Centers for Medicare & Medicaid Services (CMS) describes the process for off-campus hospital provider-based departments (PBDs) to maintain their grandfathered status when relocating due to extraordinary circumstances.

Under CMS’ finalized policy, grandfathered off-campus hospital PBDs — those that billed Medicare for services furnished before Nov. 2, 2015 — that relocate after that date normally will lose their excepted status. However, CMS indicated that in limited circumstances, grandfathered off-campus PBDs could keep their grandfathered status. Acceptable reasons for relocation might include natural disasters, significant public health and public safety needs, and seismic building code requirements.

CMS’ guidance instructs hospitals relocating a grandfathered PBD to apply for an extraordinary circumstances exception to their assigned CMS regional office (RO). For off-campus PBDs that relocated between Nov. 2, 2015, and Dec. 31, 2016, the deadline to submit a request to their RO is Jan. 31. Off-campus PBDs relocating on or after Jan. 1, 2017, must submit a relocation exception request within 30 days of the occurrence of the circumstance that necessitated the relocation.

In addition to these deadlines, the document contains details on:

  • required information the hospital should provide to the RO in its request;
  • supporting documentation the hospital should submit with the request; and
  • contact information for RO staff.

ROs will evaluate requests on a case-by-case basis and notify hospitals of their decision in writing. Contact Director of Policy Erin O’Malley at eomalley@essentialhospitals.org or 202.585.0127 with questions.

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About the Author

Shahid Zaman is a senior policy analyst at America's Essential Hospitals.