AHA urges CMS to reduce burden on national provider identifier requirements for hospital off-campus PBDs

The AHA March 24 commented to the Centers for Medicare & Medicaid Services on upcoming requirements from the Consolidated Appropriations Act of 2026 regarding hospital off-campus provider-based departments. The requirements mandate that hospitals obtain a unique national provider identifier for each of their off-campus PBDs and submit an attestation of compliance. The AHA urged CMS to implement the provisions in the least burdensome way possible to avoid overly complex processes. "The AHA has consistently raised concerns about policies that require separate NPIs for each off-campus PBD, both because it would be administratively burdensome to providers (some of whom have many off-campus PBDs) and also because it is unnecessary," the AHA wrote. "For example, CMS can already identify the exact location in which outpatient services are furnished to a Medicare beneficiary - such information is readily available in claims data and providers' enrollment information. Moreover, requiring separate NPIs will result in other unnecessary complexities for providers because NPIs are used in a wide variety of ways and on many different hospital platforms."

The AHA provided a series of recommendations to CMS to reduce as much burden as possible when implementing the provisions.