News: New requirements for off-campus outpatient departments coming

The passage of the Consolidated Appropriations Act last month will bring some changes to the Medicare provider-based billing requirements. This act funds federal departments and agencies, including the Department of Health and Human Services, for the 2026 fiscal year.

Off-campus outpatient departments will see changes in requirements. These departments are located more than 250 yards from the hospital’s main campus or from a remote location of the hospital. Effective January 1, 2028, hospitals with these departments must obtain a National Provider Identifiers (NPI) for each—separate from that of the NPI of the main provider. Items and services provided in off-campus outpatient department will be required to be billed under each respective NPI.

For off-campus outpatient departments to continue receiving Medicare payments under the Outpatient Prospective Payment System (OPPS), hospitals will need to submit an initial provider-based attestation for items and services furnished at the departments. Attestations verify the accuracy and completeness of information, particularly health information that is protected under HIPPA.

Before, submitting a provider-based attestation was voluntary. Now, hospitals will be required to confirm departments are in compliance with provider-based requirements through attestation. The initial attestation must now be submitted within two years prior to the date on which items or services are furnished.

If a hospital plans to claim and receive OPPS-based reimbursement for items and services furnished at off-campus departments on January 1, 2028, they must submit the initial attestation between now and December 31, 2027. Hospitals will then have to submit subsequent attestations for each off-campus department on a periodic basis, determined by the Secretary of the Department of Health and Human Services. CMS will also establish a process for reviewing attestations to assist.

Editor’s note: To read the full act, click here. To read additional coverage of this study from JustCoding, click here.