Elevance’s site-of-care rules put hospital revenue cycles on alert

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As Elevance Health prepares to implement new site-of-care billing requirements, revenue cycle leaders are raising concerns about additional administrative burdens, potential payment delays and growing complexity across payers.

“My broader concern is growing variation across payers, which adds cost and creates more chances for error,” Felix Segre, director of revenue integrity at Houston-based Memorial Hermann Health System, told Becker’s. “The opportunity is stronger location governance across the health system.”

Elevance announced Sept. 29 that it will require hospitals to identify the physical location where care was provided on billing forms and adjust reimbursement for certain off-campus services. The policies will apply across its commercial, Medicare Advantage and Medicaid plans, with implementation continuing through the end of 2027.

The changes could introduce additional challenges for hospital revenue cycle teams, particularly when billing information does not align with payer records, according to Mr. Segre.

“From an enterprise standpoint, I expect greater scrutiny of whether claims accurately reflect where care occurred,” he said. “That could mean added billing checks, more rework and payment delays when location details do not match payer records.”

The financial implications remain uncertain, however. Mr. Segre said any reimbursement impact will depend on the final policy and contract terms.

To prepare, he emphasized the importance of collaboration across revenue integrity, managed care, enrollment, patient access and technology teams. Those teams should work together to confirm payer requirements, validate location records and test the information transmitted to insurers.

Hospital and professional billing teams should also coordinate while maintaining their distinct billing requirements.

Ultimately, Mr. Segre said health systems should look beyond technical compliance when evaluating their response to evolving site-of-care policies.

“Success should be measured by fewer denials, less manual work, and accurate payment, not simply whether a new claim field is populated,” he said. 

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