New PO Modifier for Outpatient Therapy?

In November 2014, the Centers for Medicare and Medicaid Services (CMS) released the final rules for the outpatient prospective payment system (OPPS) and the Medicare Physician Fee Schedule (MPFS) for calendar year (CY) 2015. In the OPPS final rule, CMS finalized they will begin to collect data on services furnished in off-campus provider-based departments in CY 2015. Hospitals will be required to report the HCPCS “PO” modifier with every code on facility claims for outpatient hospital services furnished in off-campus provider-based departments. Reporting will be voluntary for CY 2015, mandatory reporting will start January 1, 2016.

The question I am receiving from hospital providers is does this final rule and the mandatory use of the PO modifier beginning January 1, 2016 apply to outpatient therapy services that are furnished in off-campus facilities? The answer is