What General Counsel and Business Leaders Need to Know:

  • Separate NPI for Each Location: Starting January 1, 2028, each off-campus hospital outpatient department covered by the Consolidated Appropriations Act of 2026 must have its own unique National Provider Identifier (NPI) rather than billing under the main hospital's NPI. Large multi-campus hospitals and systems may need hundreds of new NPIs, and billing systems must be updated so claims carry the correct one.
  • Mandatory Attestation: Existing off-campus outpatient departments must submit an attestation confirming compliance with the provider-based regulation by December 31, 2027. Those that file by that date can keep billing as provider-based while the Centers for Medicare & Medicaid Services reviews the attestation.
  • Consequences of Not Filing: A hospital that does not file an attestation or use a separate NPI for an applicable location loses the ability to be paid as part of the hospital under the preferential Outpatient Prospective Payment System reimbursement scheme at that location, even if the location has been a grandfathered location for years.

In this episode of Diagnosing Health Care®, Epstein Becker Green attorneys David M. Johnston, Allen R. Killworth, and Shannon K. DeBra discuss the new attestation and separate NPI requirements for off-campus hospital outpatient departments under the Consolidated Appropriations Act of 2026; what hospitals must do before the January 1, 2028, deadline; and open questions they are hearing from clients.

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Epstein Becker Green is a national law firm that focuses its resources on health care, life sciences, and workforce management solutions, coupled with powerful litigation strategies. This video is for informational purposes only and does not constitute legal advice. Viewing this video does not create an attorney-client relationship. 

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