Off-Campus Provider-Based Departments: Compliance and Enrollment

This article explains what makes a clinical location an off-campus provider-based department under federal regulations, what that designation requires, and what it means for naming, enrollment, Epic, and ongoing compliance. It is intended for service line administrators, anyone involved in opening or relocating a clinic, and anyone responsible for Epic department configuration.

A Note on Terminology

In federal regulatory language, provider refers to the hospital or health system as an institution — not to an individual clinician. A main provider is the institutional entity (here, UAMS) that creates or acquires another location to deliver care under its name, ownership, and financial and administrative control. Provider-based means a location operating in that relationship to the main provider.

This is distinct from how UAMS uses provider internally to refer to individual clinicians such as physicians, nurses, and advanced practice providers. Throughout this article, provider carries the regulatory meaning unless otherwise specified.

The Three Location Types

How much the Centers for Medicare and Medicaid Services scrutinize a location’s name and operations receive depends on which of three categories it falls into.

On-campus provider-based locations are those on the UAMS Medical Center campus. Under 42 CFR §413.65(a)(2), “Campus means the physical area immediately adjacent to the provider’s main buildings, other areas and structures that are not strictly contiguous to the main buildings but are located within 250 yards of the main buildings, and any other areas determined on an individual case basis, by the Centers for Medicare and Medicaid Services regional office, to be part of the provider’s campus.” Locations that meet this definition operate under the main facility’s existing enrollment. No separate CMS enrollment is required, and CMS imposes no naming constraint. Name these locations according to the conventions in the clinical location naming article.

Freestanding (non-provider-based) clinics are not integrated with any main provider as a department or provider-based entity. They do not carry provider-based designation and are not subject to provider-based regulations. CMS imposes no naming constraint on these locations either.

Off-campus provider-based locations are outside the campus boundary but operate under UAMS’s name, ownership, and financial and administrative control. These require separate CMS enrollment, and that enrollment has significant downstream implications for naming, signage, patient notification, and ongoing attestation. The remainder of this article focuses on this category.

Requirements for Off-Campus Provider-Based Status

A location seeking off-campus provider-based status must meet all of the requirements in 42 CFR §413.65(d) — which apply to all provider-based locations — plus the additional requirements in 42 CFR §413.65(e), which apply specifically to off-campus locations.

Requirements Applicable to All Provider-Based Locations (42 CFR §413.65(d))

• Licensure. The location and the main provider operate under the same license, except where state law requires otherwise.
• Clinical integration. Professional staff have clinical privileges at the main provider; medical records are integrated into the main provider’s retrieval system; inpatient and outpatient services are coordinated; medical staff committees at the main provider are responsible for quality assurance and utilization review.
• Financial integration. The location’s financial operations are fully integrated within UAMS’s financial system, with shared income and expenses, and the location’s financial status is identifiable in UAMS’s trial balance.
• Public awareness. The location is held out to the public and other payers as part of UAMS Medical Center. Patients entering the location are aware they are entering the main provider and are billed accordingly. See the Name Consistency section below.

Additional Requirements for Off-Campus Locations (42 CFR §413.65(e))

• Ownership and control. The location is 100 percent owned by UAMS, shares the same governing body, operates under the same organizational documents, and is subject to UAMS’s final authority over administrative decisions, contracts, personnel, and medical staff appointments.
• Administration and supervision. The location operates under the same monitoring and oversight as any other UAMS department, with the same frequency and intensity of reporting. Administrative functions — billing, records, HR, payroll, benefits, salary structure, purchasing — are integrated with UAMS’s.
• Location. The facility must be within a 35-mile radius of the UAMS Medical Center campus, or meet one of the alternative location criteria specified in §413.65(e)(3).

Physical Space Requirements

The Centers for Medicare and Medicaid Services requires that each off-campus provider-based enrollment correspond to a physically distinct space. In practice this means:

• Its own suite with its own suite number
• Its own waiting room — this is the requirement CMS focuses on most in practice
• Its own mailing address
• Shared hallways, elevators, and common areas are permitted

Where multiple specialties or service lines occupy the same open floor plan, they cannot be enrolled as separate off-campus provider-based departments. They must be enrolled as a single department.When submitting an attestation for an off-campus location, CMS requires supporting documentation including floor plans and photographs showing the patient-facing space, waiting area, signage, and nursing station.

Patient Notification Requirements

Under 42 CFR §413.65(g)(7), when a Medicare beneficiary is treated at an off-campus provider-based location, the hospital must provide written notice before the delivery of services disclosing:

• The amount of the beneficiary’s potential financial liability, or if the exact services are not yet known, an explanation that the beneficiary will incur a coinsurance liability to the hospital that they would not incur at a freestanding facility, along with an estimate based on typical charges
• A statement that the patient’s actual liability will depend on the actual services furnished

The notice must be readable and understandable. If the beneficiary is unable to receive it, it must be provided to their authorized representative. In emergency situations, notice must be given as soon as possible after the emergency has been ruled out or stabilized.

In plain terms: there must be a sign on the wall stating the location is part of UAMS Medical Center, and there must be a notice at the front desk informing patients they will be charged a facility fee.

The Enrollment Process

Provider enrollment is handled by UAMS’s provider enrollment team. The chief financial officer is the authorized individual who has final authority to submit enrollment forms to the Centers for Medicare and Medicaid Services.

For on-campus locations, the provider submits an attestation stating the location meets the 42 CFR §413.65(d) criteria and maintains documentation available to CMS upon request.

For off-campus locations, the provider submits an attestation stating the location meets both 42 CFR §413.65(d) and 42 CFR §413.65(e) criteria, and must supply the supporting documentation at the time of submission — not on request afterward. CMS reviews the attestation and documentation and issues a written determination.

Once a complete attestation is submitted, the location may bill and be paid as provider-based while the determination is pending. If CMS subsequently determines the location does not qualify, it will recover the difference between what was paid and what would have been paid had the location been treated as freestanding.

Change of Ownership

When UAMS acquires an existing facility that already holds a Medicare PTAN (Provider Transaction Access Number), it may have the option to assume ownership of that PTAN through a change of ownership rather than enrolling for a new one. This is significant because a new enrollment may require the facility to go without Medicare reimbursement for months — sometimes up to six months — while the enrollment is processed and survey requirements are met, with no ability to back-bill for services rendered during that period. A change of ownership, by contrast, may allow UAMS to assume the existing PTAN on the day of acquisition and back-bill from that date once the enrollment change is approved.

Epic Implications

Off-campus provider-based departments appear on professional claims with place of service 19 — the billing code that designates an off-campus outpatient hospital department. Contact the manager of clinical information systems in IT Patient Systems with questions about how this is surfaced within Epic.

Regardless of whether a location is on-campus or off-campus, the External Name field in the Epic department record must include the UAMS Health prefix. The External Name is what patients see in MyChart and other patient-facing contexts.

340B

The 340B Drug Pricing Program allows eligible covered entities to purchase outpatient drugs at significantly reduced prices. Whether a given location qualifies under 340B depends on its enrollment relationship — specifically, which Medicare PTAN it is associated with, and whether that entity meets 340B eligibility criteria.

This is a factor in how some locations are structured. Contact the chief pharmacy officer with questions about 340B eligibility and timing.

2028 Attestations

The Centers for Medicare and Medicaid Services is implementing an online attestation system for off-campus provider-based locations. Beginning in 2028, UAMS will be required to actively attest — on an ongoing basis — that each off-campus provider-based location continues to meet all applicable requirements. Locations selected for audit will need to produce supporting documentation.

The documentation CMS focuses on includes:

• Evidence that the enrolled name matches all patient-facing contexts
• Evidence of the management structure (the location is managed under UAMS Medical Center’s authority)
• Floor plans and signage photographs
• Medical record and billing integration

Maintaining this documentation now — rather than assembling it under audit pressure in 2028 — is the practical preparation.

Name Consistency

The name filed with the Centers for Medicare and Medicaid Services in the enrollment attestation must match every patient-facing instance of the location’s name: the website, marketing materials, signage on the door, and the building directory. This flows from the public awareness requirement at 42 CFR §413.65(d)(4).

CMS addressed the importance of naming directly in the preamble to the 2000 final rule that established 42 CFR §413.65, rejecting the argument that naming should be a marketing decision: operating under the name of the main provider, CMS stated, “is an important indicator of status as an integral and subordinate part of that provider.” A location that presents itself under a different name risks failing the public awareness criterion and losing provider-based status.

The naming decision for an off-campus provider-based location should be made deliberately, in coordination with provider enrollment, before the attestation is submitted — because once it is, the name is effectively locked. Changing it requires a new enrollment action and corresponding updates to every patient-facing context where the name appears.

For guidance on how to form the name itself, see the clinical location naming conventions article.

See Also

• Clinical Location Naming Conventions
• 42 CFR §413.65
• 65 FR 18434 (Apr. 7, 2000)