Bipartisan Budget Act Section 603's Impact on Off-campus Hospital Departments

February 152016Bipartisan Budget Act Section 603's Impact on Off-Campus Hospital Departments

340B covered entities, in the process of or considering acquisition and/or development of new off-campus outpatient locations, should evaluate the impact of the Medicare payment changes in Section 603 for “site-neutral” locations.

Alinea is participating in several key discussions with policy makers and legal analyst to understand how HRSA will interpret the statutory changes. The changes would likely impact 340B eligibility for off-campus outpatient departments created after the date of enactment of the provision. Current 340B Program policy extends access to 340B discounts to only those outpatient locations of an eligible coverted that are reported as Medicare-reimbursable outpatient locations on the hospital’s Medicare cost report. However, based on reports, “site-neutrals” may be allowed to be reported as provider-based per the Medicare Cost Report in order to allow 340B hospitals continued 340B access for these outpatient sites.

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