Last mentioned: Feb 25, 2026
Enforcement Begins
Mandatory NPI and attestation requirements take full effect for Medicare reimbursement eligibility.
Enforcement Begins
Medicare payments will be withheld from off-campus HOPDs that lack a unique NPI and valid attestation.
Attestation Deadline
Final date for hospitals to submit initial provider-based attestations for existing off-campus sites.
Initial Filing Deadline
Final day for hospitals to submit initial attestations for all existing off-campus departments.
Legislation Enacted
President signs the Consolidated Appropriations Act of 2026, ending the voluntary attestation era.
Legislation Enacted
President signs the Consolidated Appropriations Act of 2026 into law.
CMS Rulemaking
CMS expected to establish the formal process and portal for NPI and attestation submissions.
The Consolidated Appropriations Act of 2026 mandates that all off-campus hospital outpatient departments (HOPDs) obtain unique National Provider Identifiers and submit formal provider-based attestations. This regulatory shift ends the long-standing voluntary compliance system and sets a hard enforcement deadline of January 1, 2028.
The Consolidated Appropriations Act of 2026 mandates that all off-campus hospital outpatient departments (HOPDs) obtain unique National Provider Identifiers and submit formal compliance attestations. Hospitals must meet these new transparency requirements by January 1, 2028, to maintain eligibility for Medicare payments under the Outpatient Prospective Payment System.