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As you know, Murer Consultants, Inc. continues to follow regulatory developments at both a state and federal level to better serve our current and prospective clients. In light of that priority, we wish to update you all on a recent development important to Illinois hospital providers.
On November 29, 2010, the Illinois Department of Healthcare & Family Services (HFS) issued a proposed rule that would permit provider-based Medicaid reimbursement at off-campus sites, much like the Medicare program. The proposed rule would allow HFS to reimburse hospital clinics or outpatient departments that are not located on a hospital campus at the same rate as on-campus sites.
If this regulation is finalized as is, it would modify an existing regulation, which requires the site to be adjacent to or on the premises of the hospital and be licensed under Illinois law. In addition to the potential for increased Medicaid reimbursement, the proposed rule change would provide much needed consistency between Medicare and Medicaid billing procedures for off-campus provider-based sites. Under the proposed rule, a hospital clinic or outpatient department would qualify for Medicaid reimbursement for hospital outpatient services if the site meets provider-based status under Medicare pursuant to 42 C.F.R. § 413.65.
Murer Consultants has experience assisting hospitals in meeting provider based status requirements under Medicare and integrating on and off campus operations. We are well suited to do so under the proposed Medicaid regulation as well.
Please be mindful of the fact that this is still a proposed rule and is subject to administrative procedures outlined below. The Illinois Administrative Procedure Act requires HFS to comply with notice of proposed rulemaking requirements, which last a minimum of 90 days, and can take up to one year. At the earliest, the proposed rule could be finalized by February 27, 2011. However, this process can be fairly unpredictable. We will continue to monitor the proposed rule and advise you of any updates.
If you have any questions, comments, or concerns, please contact your consultant or our office at (815) 727-3355.
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