Prepare a class readiness paper with your analysis of hospital systems. Hospital analysis includes a discussion of the Anti-Kickback Statute, the Stark Law, changes in the reimbursement policies under PPACA, and medical subpractice and tort reform.
Papers should be formatted with headings:Topics for next week on hospital analysis: 
Industry analysis 
Market share 
My topic only Industry analysis and Market share for Hospital Analysis Need brief for this topics only
Hospitals and Health Systems:
Provider-Based Status:
The Rules and Common Issues
Elissa Moore, Associate
312.750.5736 | [email protected]
77 West Wacker Drive, Suite 4100
Chicago, Illinois 60601-1818
www.mcguirewoods.com
Bart Walker, Associate
704.373.8923 | [email protected]
Bank of America Corporate Center
100 North Tryon Street, Suite 2900
Charlotte, North Carolina 28202-4011
Elissa Moore and Bart Walker are associates based in the Chicago, IL and Charlotte, NC offices of the McGuireWoods LLP Health Care
Department.
Hospitals focused on growth and development are increasingly interested in providing services off-site of the main
campus of the hospital. Moving off-campus can be driven by a number of factors, including: space limitations on
the main campus, patient needs, population growth, convenience and other competitive factors. Other hospitals,
constrained in existing buildings, are looking to construct and grow on campus. Whether moving off-campus or
building on-campus, hospitals must ensure that they satisfy Medicare’s provider-based status rules (“Provider-Based Rules”)
in order to continue to be able to bill for the services provided at the new locations under the hospital’s Medicare number.
It is important for hospitals to be able to bill under their existing Medicare number because the payment the hospital
receives is typically higher than it would be in a clinic or office setting. As a result, the ability to qualify for provider-based
status is a critical piece of the economic puzzle for hospitals considering expansion or acquisition of off-campus facilities.
The consequence of failing to qualify for provider-based status is that the new facility will be required to have its own
Medicare number to seek reimbursement. As stated above, non-provider-based facilities typically experience much lower
reimbursement rates than the hospital rate. It is also important to note that the provider-based rules apply to entire facilities,
rather than particular services.
A provider-based facility is a facility that is operationally integrated with a main hospital (i.e., it operates under the same
name, ownership, and administrative and financial control of the main hospital) such that it is permitted to bill for services
under the hospital’s provider number. There are a number of requirements that a facility has to satisfy in order to be deemed
provider-based, particularly if the facility in question is a joint venture with a non-hospital party or parties. This article
outlines the provider-based status rules and provides case study illustrations of the provider-based status rules in operation to
highlight common questions that arise in provider-based status situations.