CMS proposes mandatory attestation process for off-campus provider-based departments
CMS is advancing a proposed rule that would mandate a new attestation process for off-campus outpatient departments claiming provider-based status. The rule would codify specific requirements for providers to certify compliance with Medicare’s provider-based department regulations, including space, staffing, and billing integration. This formalization, building on earlier compliance guidance, is part of the agency's broader efforts to enforce site neutrality and ensure that higher reimbursements for hospital outpatient settings are justified. The proposal will be subject to a public comment period. Review the proposed attestation criteria for any outpatient locations you operate to assess potential compliance exposure ahead of the final rule.