Bass, Berry & Sims member Travis Lloyd will present an educational session to the Florida Hospital Association (FHA) on Tuesday, August 18, from 11:00–12:00 p.m. CT, addressing new federal requirements affecting off-campus hospital outpatient departments (HOPDs).
Under the Consolidated Appropriations Act of 2026, hospitals will soon be required to obtain and use a separate National Provider Identifier (NPI) for each off-campus HOPD and submit a provider-based attestation for each location. These changes will require hospitals to review their current enrollment, billing and compliance processes and prepare for implementation.
During the session, Travis will discuss the new statutory requirements for off-campus HOPDs, related proposals outlined in CMS’s Hospital Outpatient Prospective Payment System Proposed Rule, and the potential enrollment, billing, reimbursement, operational and compliance implications for hospitals. He will also address steps hospitals should be taking now to prepare for the upcoming changes.