Off-Campus Outpatient Departments: CMS’ Proposed Rule for the New Mandatory Attestation Process

Short summary

CMS issued proposed regulations implementing Section 6225 of the Consolidated Appropriations Act, requiring off-campus hospital outpatient departments to obtain separate NPIs and submit mandatory attestations starting January 1, 2028. The proposed rule standardizes the attestation process, introduces a centralized electronic submission system, and offers relief by deeming timely submission as compliance even if CMS hasn't issued a determination. Comments are due by August 31, 2026.

• •CMS proposes mandatory NPI and attestation requirements for off-campus hospital outpatient departments effective 2028
• •Standardized attestation form and centralized electronic submission system planned
• •Timely submission of initial attestation deemed compliant even without CMS determination by deadline

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