Demystifying Hospital Provider-Based Status: Regulatory Requirements, Process Complexities, Pitfalls to Avoid
A live 90-minute CLE video webinar with interactive Q&A
This CLE webinar will examine what is involved in acquiring and maintaining provider-based status for facilities or departments of hospitals. The panel will examine regulatory requirements and provide a comprehensive overview of the process of establishing and maintaining provider-based locations. The panel will discuss the risks and benefits, related compliance considerations, and best practices for guiding clients in this complex area.
Outline
- Introduction
- Provider-based regulatory authority
- Covered providers
- Qualifying as a provider-based location
- CMS provider-based requirements
- Provider-based determinations
- Provider-based attestations
- Pros and cons of provider-based status
- State law considerations
- Latest regulatory updates
- Best practices and pitfalls to avoid
Benefits
The panel will review these and other important considerations:
- When may a healthcare provider seek provider-based status for an off-campus location?
- What are the pros and cons of provider-based status?
- What are the regulatory requirements for becoming a provider-based location? How extensive is the process?
Faculty

Emily J. Cook
Partner, Healthcare Regulatory & Compliance Practice Area Leader
McDermott Will & Emery
In addition to Ms. Cook’s role as a national authority on the 340B drug pricing program, she helps clients... | Read More
In addition to Ms. Cook’s role as a national authority on the 340B drug pricing program, she helps clients navigate the full suite of federal and state regulations that are essential to healthcare operations. Ms. Cook partners with a wide range of organizations, including non-traditional service providers and new market entrants to identify, protect and expand revenue opportunities, including via private-equity-backed ventures. Her comprehensive counsel encompasses evolving issues such as No Surprises Act implementation, development of new provider types, Medicare provider-based and co-location rules, and trends in qui tam litigation and government investigations. Ms. Cook’s deep insights into U.S. healthcare regulation stem from her previous tenure at the HHS Health Resources and Services Administration.
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Sandra M. DiVarco
Partner
McDermott Will & Emery
Ms. DiVarco focuses her practice on the representation of hospitals and health systems. She counsels healthcare... | Read More
Ms. DiVarco focuses her practice on the representation of hospitals and health systems. She counsels healthcare facility and system clients regarding all aspects of health law transactions and health system restructurings. She has a deep knowledge of regulatory, licensing and accreditation issues of particular concern to healthcare providers. She regularly advises clients on the legal aspects of clinical regulatory issues and policy/procedure and operational matters. She is a registered nurse, and holding a current license in Illinois, she brings a pragmatic perspective and first-hand knowledge of health care operations to these complex and mission-critical matters.
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Caroline Reignley
Partner
McDermott Will & Emery
Ms. Reignley provides strategic legal, regulatory and compliance counsel to for-profit and nonprofit hospitals, health... | Read More
Ms. Reignley provides strategic legal, regulatory and compliance counsel to for-profit and nonprofit hospitals, health systems, other healthcare providers, life sciences and technology companies. She counsels clients on interpretation and risk mitigation under the Anti-Kickback Statute, Stark Law and EKRA. She also advises on internal and government investigations related to the False Claims Act, Stark Law and Anti-Kickback Statue. Ms. Reignley advises clients involved in digital health on the applicable legal and regulatory infrastructure, with a particular focus on remote patient monitoring programs. She also advises Medicare providers, consultants and vendors on a wide range of business, legal and regulatory issues. She has extensive experience advising clients on Medicare and Medicaid fee-for-service reimbursement, billing and coding. She also advises clients on professional licensure, scope of practice, physician and health care professional clinician relationships and supervision, together with overall corporate compliance.
CloseEarly Discount (through 03/21/25)