I am looking for assistance with the cost report treatment for our new intensive cardiac rehabilitation service. This service is provided in an off-campus provider-based location, and it was required to be separately enrolled by the Medicare program because the service must be performed by an approved provider.
Our Medicare enrollment was approved, as we are a licensee of the national Ornish program. Per the Medicare Program Integrity Manual, we will be receiving a separate Provider Transaction Access Number (PTAN) for this service. Can this be included in the cost report or does it have to be below the line? In all other respects, this service operates like a department of the hospital and the new PTAN is under the hospital tax ID and the National Provider Identifier (NPI).
Answer: Under the assumption the clinic meets the criteria for provider-based clinics (section 413.65 of the Code of Federal Regulations), the area would be reported on a separate reimbursable line with a billing PO modifier (services, procedures, and/or surgeries furnished at off-campus provider-based outpatient departments) with every HCPCS code for all outpatient items and services furnished in an off-campus provider-based department of a hospital.
Medicare Administrative Contractors have given emphasis to provider-based settings especially if the 340B Drug Discount Program is in the picture. This response is based upon the facts you’ve provided. I don’t believe the PTAN would come into play unless the services are billed as provided at a freestanding facility. Then it would be included on the non-reimbursable line.
This question was answered by: David A. Williams, FHFMA, CPA, partner, Horne LLP, and a member of HFMA’s Mississippi Chapter.
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