COVID-19's impact on provider-based departments

Kathleen Spears (kathleen.spears@ankura.com) is Director, Risk, Forensics & Compliance, and Charden T. Virgil (charden.virgil@ankura.com) is Senior Associate, Risk, Forensics & Compliance, at Ankura Consulting Group LLC in Chicago.

The one constant in healthcare is change, and the COVID-19 public health emergency (PHE) brought rapid change to how and where hospitals deliver services to patients. Healthcare entities may have relocated or temporarily shifted provider-based departments (PBDs) to provide flexibility for patient care purposes. When the PHE ends (and the associated 1135 waivers), will your organization still have a solid physical inventory of all your hospital spaces and PBDs? Do those temporary relocations become permanent changes? Will the new location become “non-excepted” and affect reimbursement? Who in your organization is providing oversight and a road map for these changes? Does your organization’s leadership have a master list of each provider-based location? If you answered yes to any of these questions, continue reading, as the discussion will focus on important considerations to Medicare’s requirements for PBDs considering the COVID-19 pandemic.

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