Demystifying Hospital Provider-Based Status: Regulatory Requirements, Process Complexities, Pitfalls to Avoid

Healthcare systems and hospitals are often faced with the dilemma of whether to treat locations outside of a main hospital provider's physical location as separate entities or to seek designation as a provider-based location of the main provider. "Provider-based" is a Medicare payment designation that allows facilities that are owned and operated by a main provider to bill Medicare as a department of that provider which may result in receiving higher payments or other beneficial treatment.

However, the process of deciding whether to make a department or facility a provider-based location--examining the pros and cons, understanding the requirements and the process for being designated as provider-based--and establishing compliance with the provider-based requirements is time consuming and complex.

For example, organizations seeking the provider-based status for a location may request a determination from CMS confirming that they meet the regulatory requirements. Part of that process may include preparing a provider-based attestation, a submission that can be hundreds of pages long and generally must include voluminous supporting documents.

Listen as our expert panel provides a comprehensive overview of the requirements and complexities of seeking provider-based status for hospital locations. The panel will discuss pros and cons of provider-based status and offer best practices for guiding clients through the complex process and mitigating the risk of noncompliance.

1. Introduction
   1. Provider-based regulatory authority
   2. Covered providers
2. Qualifying as a provider-based location
   1. CMS provider-based requirements
   2. Provider-based determinations
   3. Provider-based attestations
   4. Pros and cons of provider-based status
   5. State law considerations
3. Latest regulatory updates
4. Best practices and pitfalls to avoid

The panel will review these and other important considerations:

• When may a healthcare provider seek provider-based status for an off-campus location?
• What are the pros and cons of provider-based status?
• What are the regulatory requirements for becoming a provider-based location? How extensive is the process?