"Prove It or Lose It Provider-Based Compliance After Section 6225," Health Law Pulse Series, Davis Wright Tremaine Webinar
Provider based status has long been an important component of hospital reimbursement strategy, but CMS's optional attestation requirement has enabled many hospitals to avoid regulatory scrutiny for non-compliance. Section 6225 of the Consolidated Appropriations Act, 2026 significantly changes this compliance landscape by introducing new provider-based requirements that are directly linked to Medicare reimbursement. Under the new legislation, a hospital seeking Medicare reimbursement for items and services furnished in an off-campus hospital outpatient department must (1) obtain a National Provider Identifier (NPI) for that department that is separate from the hospital's main NPI, and (2) submit a provider-based attestation demonstrating the department's compliance with the provider-based status rules. Beginning January 1, 2028, Medicare reimbursement to the department will cease until these requirements have been met.
In this webinar, Darby Allen and Marci Love will break down what provider based status means, why it matters financially, and how federal oversight is tightening—particularly for off campus outpatient departments. They will walk through the new compliance requirements and the key steps hospitals must take before the 2028 deadline to avoid losing Medicare reimbursement.
This session is designed for healthcare executives, compliance officers, reimbursement specialists, and legal professionals advising hospitals and health systems.
This webinar is the fourth installment of DWT's Health Law Pulse—a monthly series that will keep you current on the health law landscape for 2026. View our previous sessions, "Preparing for the Storm: Legal Strategies to Maximize Commercial Payor Reimbursement as Government Payments Are Expected to Decline," "Health Information Exchange Today: Privacy Considerations and Industry Trends" and "Medicare & Medi-Cal in 2026: Key Payment Updates Every Provider Should Know."
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