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New Provider-Based/HOPD Requirements: How to Prepare

July 16, 2026

This webinar will provide an overview of new requirements enacted in the Consolidated Appropriations Act, 2026, affecting off-campus hospital outpatient departments (HOPDs), also known as provider-based departments. Beginning January 1, 2028, each of these departments will be required to bill under a separate National Provider Identifier (NPI) and attest to meeting CMS’ provider-based requirements. The session will also explore anticipated CMS guidance, the potential for increased audit scrutiny, and the importance of early coordination across reimbursement, IT, and finance teams to successfully navigate this requirement.

Learning Objectives

Upon completion of this program, participants will be able to:

  • Recognize the new attestation and NPI requirements and their potential operational and financial impacts.
  • Describe the expected proposed regulations in the 2027 Outpatient Prospective Payment System (OPPS) rule regarding implementation of these requirements.
  • Identify practical steps hospitals should take now to help prepare for compliance and avoid Medicare payment suspensions.

Presenter(s)

Jill Griffith-Goodwin, Chad Mulvany

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