Separate Identification Number and Attestation Requirement for Each Off-Campus Provider-Based Outpatient Department
Section 6225 of the Consolidated Appropriations Act of 2026 requires the following:
- Each off-campus provider-based outpatient department must obtain and bill under its own National Provider Identifier (NPI) beginning January 1, 2028.
- Hospitals must submit between January 1, 2026, and December 31, 2027, an initial provider-based attestation of compliance with the requirements described in 42 CFR 413.65 for each off-campus location.
- CMS will establish through notice and comment rulemaking a process for submitting initial and subsequent attestations and for verifying compliance through site visits, remote audits, or other appropriate means.
What hospitals should do now:
- Identify all off-campus provider-based outpatient departments
- Obtain a separate NPI for each off-campus provider-based location
- Evaluate each department’s compliance with the regulations and correct any deficiencies prior to submitting a provider-based attestation
- Attestation guidance and checklists are located at https://dominoapps.palmettogba.com/palmetto/jja.nsf/DID/SYHGWL1LRJ
- Gather the required documentation to submit with the attestations
- Monitor CMS rulemaking for updated attestation and submission processes
- Continue to monitor each department’s compliance with the provider-based requirements
For more information, please contact our Albany office at (229) 883-7878 or our Atlanta office at (404) 220-8494.
Access all Client Alerts by clicking here.