CMS final rule mandates NPI attestation for off-campus hospital outpatient departments
CMS finalized its framework requiring all off-campus provider-based departments (PBDs) to submit a mandatory attestation and obtain a separate National Provider Identifier (NPI). The rule, included in the 2027 Hospital Outpatient Prospective Payment System, aims to enforce site-neutral payment policies and clarify billing location status. Facilities must attest to their off-campus status and report specific service-line information. Failure to comply will affect Medicare reimbursement for services furnished at non-compliant locations. Practices billing under hospital outpatient department arrangements should immediately verify their PBD's attestation status and prepare to submit required data by the CMS deadline, which is expected before the 2027 calendar year.