Provider-Based/HOPD Requirements Finalized: Key Next Steps
November 18, 2026CMS has finalized regulations implementing new requirements for provider-based/off-campus hospital outpatient departments (HOPDs) from the Consolidated Appropriations Act, 2026, and hospitals have a limited window to prepare. Beginning January 1, 2028, hospitals must ensure that each off-campus HOPD bills Medicare under its own National Provider Identifier (NPI) and submits an attestation confirming compliance with CMS’ provider-based requirements. These requirements will increase operational, compliance, and reimbursement risks for hospitals that have not fully documented and validated their locations’ provider-based status and obtained separate NPIs.
This webinar will review the relevant provisions from the 2027 Outpatient Prospective Payment System (OPPS) final rule, discuss the potential implications for reimbursement and operations, and share steps hospitals can take to prepare for this deadline. Participants will gain practical insights into how hospitals can assess their current provider-based department structures, identify compliance gaps, and prepare for the new attestation and billing requirements before they take effect.
Learning Objectives:
Upon completion of this program, participants should be able to:
- Explain the final rule requirements for separate NPI billing and provider-based attestations for off-campus HOPDs.
- Assess the operational, compliance, reimbursement, and audit implications of the new requirements, and identify common provider-based compliance vulnerabilities that may place departments at risk.
- Develop an implementation strategy that includes coordination among reimbursement, revenue cycle, compliance, provider enrollment, finance, and IT teams to meet CMS requirements by January 1, 2028.
CPE Information
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Prerequisites & Advanced Preparation
None
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Questions
If you have questions about this CPE program, please contact us at [email protected].
If you have concerns or would like information regarding program cancellation policies or CPE credit, contact us at [email protected].
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