CMS NPI attestation rules
Medicare is rolling out new NPI and attestation requirements for hospital off‑campus outpatient departments, with compliance prep starting now for changes effective January 2028. Labs that do FNA or outreach cytology services will need to update workflows and documentation to meet the new provider identification rules. (natlawreview.com)
Section 6225 of the Consolidated Appropriations Act, 2026 amends the Social Security Act (Section 1833(t)) and was enacted as Public Law No. 119‑75 on February 3, 2026. (congress.gov) The statute now requires each off‑campus hospital outpatient department to have a distinct, location‑specific National Provider Identifier and for the hospital to submit a provider‑based attestation demonstrating compliance with the provider‑based regulations at 42 C.F.R. § 413.65. (hallrender.com) The law contemplates an initial attestation submitted within a two‑year window tied to when services are furnished and directs the Secretary of HHS to establish, by regulation, the process and timing for any subsequent periodic attestations. (dwt.com) CMS is authorized to design a submission and review process (historically routed through Medicare Administrative Contractors), to conduct compliance reviews including audits and site visits, and the statutory framework identifies overpayment recovery and enforcement mechanisms as potential consequences of noncompliance. (dwt.com) The statute also mandates that the HHS Office of Inspector General analyze the attestation review process and provide a report to Congress by January 1, 2030, creating a formal oversight checkpoint that could drive future regulatory refinements. (bakerdonelson.com) CMS defines a “hospital outreach laboratory” in its Clinical Laboratory Fee Schedule materials and applicable hospital outreach labs that bill Medicare Part B do so under their own NPIs or on Form CMS‑1450 (TOB 14x), which means laboratory billing/enrollment records and CLIA/licensure documentation will need to be reconciled against any new, location‑specific NPIs. (cms.gov) The American Hospital Association filed comments with CMS on March 24, 2026 urging that CMS minimize administrative burden related to unique NPIs and attestation procedures, signaling active stakeholder engagement that could influence how CMS implements submission mechanics and timing. (aha.org)
