Testing to Begin to Ensure Off-Campus Facility Locations Properly Reported on Patient Claims

If your hospital has off-campus, outpatient, provider-based facilities, you should be aware that Medicare has begun testing to ensure hospitals are properly reporting the service facility location on patient claims. In MLN Matters Number SE18002 , Medicare introduced the requirement that hospitals must report the service facility location for off-campus, outpatient, provider-based departments on claims effective January 1, 2017. The service facility location must be reported when all services rendered on a claim are from the same off-campus, outpatient, provider-based department of the hospital. Medicare will cross reference the address indicated on the claim with the facility locations on file in the Provider Enrollment, Chain and Ownership System (PECOS) in order to ensure that services are being performed at an enrolled Medicare location.

On October 12, 2018, the CMS released MLN Matters SE18023 regarding the Activation of Systematic Validation Edits for Outpatient Prospective Payment System (OPPS) Providers with Multiple Service Locations. This notice informed providers that a second round of testing of Fiscal Intermediary Shared System (FISS) Edits that will test for compliance with this regulation will begin in November 2018, with full implementation of the program scheduled for April 2019. 
If your hospital has off-campus provider-based departments, you should ensure the following for accurate submission of claims:

  • The hospital’s CMS-855 enrollment is up to date and all off-campus provider-based facility locations are listed in PECOS.
  • The hospital billing system is set up to include service facility locations in loop 2310E of the 837 institutional claim transactions.
  • The addresses generated on claims EXACTLY match what is listed in PECOS. 

Failure to do so could result in payment denials for services rendered at off-campus, outpatient, provider-based facilities. 
Please contact us for assistance on CMS-855 enrollments, provider-based facilities, or general questions on these Medicare regulations. 
Sara Bing, Manager
Karen Robinson, Manager
614.223.9209 x3713
614.223.9209 x3702