Bass, Berry & Sims attorney Travis Lloyd was quoted in two articles discussing how the newly passed Consolidated Appropriations Act, 2026 will impact Medicare payments for off-campus hospital outpatient departments. As Travis outlined in content written on February 4, the new law “requires hospitals to obtain and use separate National Provider Identifiers (NPIs) for each off-campus outpatient department. It also requires hospitals to submit provider-based attestations for each off-campus outpatient department.” If these actions are not taken by January 1, 2028, providers will not receive Medicare payments for services performed at these locations.
In an article for hfma, Travis noted the “new law creates real financial consequences for noncompliance” adding “It’s uncommon for a hospital system to have completed attestations for all of its off-campus facilities. Many hospitals have not gone that extra step because it just hasn’t been viewed as necessary.”
While the January 2028 deadline is two years out and despite implementation uncertainty, Travis recommends hospitals begin preparing now, saying “It’s a compliance exercise where you’re making sure that, ‘Yes, we in fact comply and we can prove it. Here’s the documentation to support it.’ That’s ultimately what the attestation is.”
As quoted in a TechTarget article outlining the changes, Travis said “site-neutral payments may be one piece of the puzzle. CMS seems to be shifting how Medicare pays for outpatient services in the long term.”
The articles quoting or written by Travis are linked below:
- “Big financial impacts from off-campus HOPD rule change, “ hfma (February 16, 2026)
- “Site-neutral payments would slash hospital funds by $182B,” TechTarget – Rev Cycle Management (February 9, 2026)
- “Congress Enacts New Attestation and Identifier Requirements for Off-Campus Hospital Outpatient Departments,” Bass, Berry & Sims (February 4, 2026)