New Medicare Billing Rules for Off-Campus Provider-Based Departments: Best Practices for Planning and Implementation

This CLE webinar will examine the new Medicare billing requirements for off-campus provider-based departments under the recently enacted Consolidated Appropriations Act of 2026 (CAA). The panel will examine the significant impact that the new requirements will have on covered stakeholders, discuss possible repercussions for noncompliance, address remaining questions, and offer best practices for implementation. 

The recently enacted CAA includes significant new Medicare billing requirements for off-campus provider-based departments. The law requires hospitals to obtain and use separate National Provider Identifiers (NPIs) for each off-campus outpatient department and also submit provider-based attestations for each. 

Historically, the submission of provider-based attestations has been voluntary. The CAA now makes the attestation process mandatory for all off-campus provider-based departments and requires hospitals to submit: (1) an initial provider-based attestation prior to Dec. 31, 2027 for any existing off-campus outpatient department of the provider; and (2) subsequent attestations in accordance with a timeframe to be specified by HHS.

Additionally, covered entities must now obtain a separate NPI for each off-campus provider-based department and items and services furnished on or after Jan. 1, 2028 in any such department must be billed under this separate NPI.

While agency rulemaking will be ongoing, counsel and their impacted clients should begin preparations now as compliance will require significant time and effort from impacted stakeholders and noncompliance will be costly (e.g., without the proper attestation, there can be no Medicare billing for services provided at the off-campus location). 

Listen as our expert panel examines the new Medicare billing requirements for hospital off-campus outpatient departments under the CAA and provides best practices for implementation.