New Compliance Requirements in Medicare Reimbursement Strategies

The status of provider-based facilities has long been integral to hospital reimbursement strategies. However, the CMS's optional attestation requirements have enabled many hospitals to bypass comprehensive regulatory oversight. With the introduction of Section 6225 in the Consolidated Appropriations Act, 2026, a new era of regulatory compliance requirements emerges, directly influencing Medicare reimbursements.

Under these provisions, hospitals are mandated to meet specific criteria for Medicare eligibility for off-campus outpatient department services. Key requirements include obtaining a separate National Provider Identifier (NPI) for each department, distinct from the primary hospital’s NPI, and providing a provider-based attestation. From January 1, 2028, facilities that fail to adhere to these guidelines will be ineligible for Medicare reimbursements.

Upcoming Webinar: Navigating New Compliance Requirements

An insightful webinar conducted by Darby Allen and Marci Love will explore the financial implications of provider-based status amid increased federal scrutiny, particularly in off-campus outpatient services. This session is pivotal for healthcare professionals needing guidance on compliance strategies to ensure uninterrupted reimbursements by the 2028 deadline.

Targeted at healthcare executives, compliance officers, and legal advisors, this discussion forms part of DWT’s Health Law Pulse series, highlighting critical trends within the health law landscape. CLE credits are pending approval in several states, offering participants the potential for credit eligibility across multiple jurisdictions. The session will be recorded for convenience, and further details on privacy practices can be accessed on the DWT website. For inquiries, please contact McKenzie Simek.