A significant policy shift is about to reshape how hospitals structure, track, and bill for their off-campus Provider-Based Hospital Outpatient Departments (PB HOPDs). With the approval of Section 6225 of the FY2026 Health Care Appropriations Bill, hospitals will soon be required to obtain a unique National Provider Identifier (NPI) for every off-campus PB HOPD and comply with updated provider-based attestation standards.
The new requirements take effect January 1, 2028, giving organizations a two-year transition window, but the work required is substantial enough that planning must begin now.
A Major Operational Change for Hospitals
Historically, hospitals have been able to bill multiple services and locations under a single hospital NPI, typically the main campus NPI. Attestations confirming provider-based compliance were voluntary, and many organizations relied on documentation alone to support the status of their off‑campus departments.
The upcoming requirements mark a clear departure from that approach. Every PB HOPD will now need its own billing NPI, whether grandfathered or newly created, and will be subject to CMS’s updated attestation process once released.
This change has many implications for billing, enrollment, credentialing, revenue cycle operations, and EHR configuration. Even small discrepancies across systems can disrupt claim processing, making data alignment essential.
Why Hospitals Must Start Preparing Now
Although CMS has not yet issued the updated attestation instructions, hospitals cannot afford to wait. The current provider-based regulations (outlined in 42 CFR §413.65) remain the foundation for future compliance, and validating location status now will reduce downstream challenges.
Equally important is ensuring that core systems and external data sources match exactly. Misaligned addresses, incorrect taxonomy codes, and inconsistent enrollment data between the EHR, NPPES, PECOS, and payors remain some of the most common causes of denials. With the new NPI requirements, that risk only increases.
Key Steps Hospitals Should Take During FY2026–FY2027
1. Reassess Provider-Based Compliance
Hospitals should reevaluate every PB HOPD against the full set of requirements in 42 CFR §413.65, regardless of previous status or historical assumptions. When CMS releases its updated attestation process, all departments will need to participate.
This step is especially important for:
- Legacy off‑campus departments
- Departments relying on older attestations
- Newly acquired or reorganized facilities
2. Conduct a System-by-System Assessment
A thorough review across all platforms is essential.
EHR Review
Hospitals should verify:
- Location configuration
- Address accuracy using exact-match standards
- Taxonomy code usage
- Whether each department is currently tied to an NPI (and whether that will change)
This review will help identify the configuration changes needed once new NPIs are obtained from NPPES.
NPPES Reconciliation
Next, organizations should compare EHR data to NPPES records to determine:
- Which PB HOPDs are already established as subparts
- Which locations require new NPIs
- Whether taxonomy codes align with both the hospital’s designation and the department’s function
Medicare PECOS System and Payor Alignment
Finally, hospitals must ensure consistency across:
- Medicare PECOS enrollment files
- Payor portals
- Payor rosters
Reconciling provider data with payor data is necessary to avoid billing disruptions later.
3. Develop a Coordinated Implementation Plan
Once the new NPIs are obtained from NPPES, hospitals will need a structured rollout that accounts for:
- EHR updates and testing
- PECOS enrollment changes
- Payor notification processes and timelines
- Verification that each payor has completed its update
- A controlled release of claims under the new NPIs
Releasing claims too early, before payor systems have fully processed the changes, is one of the biggest risks to revenue cycle leakage.
4. Create a Central Tracking and Communication Framework
An effective tracking framework should include:
- NPI status for each PB HOPD
- Required system updates
- Payor confirmations
- Internal project milestones
- Department-level responsibilities
Clear communication among compliance, revenue cycle, IT, scheduling, registration, and clinical leadership will help ensure consistency throughout the transition.
Preparing for a Complex but Necessary Transition
The upcoming NPI and attestation requirements represent one of the most significant structural changes to provider-based billing in decades. Although 2028 may seem far off, the level of effort needed across enrollment, EHR configuration, compliance, and revenue cycle teams is substantial.
Hospitals that begin preparing now will be better positioned to avoid billing delays, prevent revenue loss, and ensure a smooth transition when the mandate goes into effect. For more information or support with assessment, planning, or implementation, please contact our experts.
