A new law, the Consolidated Appropriations Act, went into effect on February 3, 2026, issuing new Medicare reimbursement guidelines for off-campus provider-based hospital outpatient departments (HOPDs). As of January 1, 2028, hospitals will be required to make certain operational changes to maintain OPPS reimbursement eligibility for their off-campus provider-based locations. These include such measures as obtaining a National Provider Identifier (NPI) separate from the hospitals’ NPI, and submitting an initial provider-based attestation demonstrating compliance with the requirements of 42 C.F.R. § 413.65.

To learn what other specific changes are needed, what qualifies as an Off-Campus Outpatient Department, and the significance of the new mandates, we urge hospitals to take a moment to read the full legal update.