• Site Neutral Medicare Payments for Off-Campus Hospital Clinics
  • August 17, 2016 | Authors: Joel M. Hamme; Barbara Straub Williams
  • Law Firm: Powers Pyles Sutter & Verville PC - Washington Office
  • This memorandum is an update on implementation of Section 603 of the Bipartisan Budget Act of 2015 (BBA 2015)1, which provides for “site neutral” Medicare reimbursement for certain off-campus outpatient clinics. On July 6, 2016, the Centers for Medicare and Medicaid Services (CMS) issued an advance copy of a proposed rule to implement Section 603. This memorandum summarizes CMS’ proposal and highlights its implications for purposes of both Medicare payment and participation in the 340B program. Comments on the proposed rule are due September 6, 2016.