Overview of the potential operational and revenue cycle implications

At the time of this post, under consideration by Congress

Congress is considering legislation that would require off-campus hospital outpatient departments (HOPDs) to bill Medicare using a National Provider Identifier (NPI) that is separate from the main hospital’s NPI.

If enacted, this requirement would change how hospitals enroll off-campus departments and submit Medicare claims for outpatient services. The proposal focuses on billing identifiers rather than changes to clinical documentation or service reporting.

Current Billing Requirements

Under existing Medicare rules, hospitals are required to identify site of care on institutional claims. Off-campus outpatient services are reported using established billing elements, including:

• Type of bill indicators
• Required HCPCS modifiers
• Service location and place-of-service reporting

These requirements are used to support payment policy and oversight across Medicare and are incorporated into current billing and compliance processes.

Proposed Change

The proposed legislation would require off-campus hospital outpatient departments to enroll and bill Medicare using a separate NPI from the main hospital.

The proposal does not introduce new clinical data elements. Instead, it introduces a new identifier requirement as part of the billing and enrollment process.

Operational Considerations

If implemented, separate NPI requirements would require hospitals to:

• Establish additional Medicare enrollment records for affected departments
• Update billing system configuration and claim submission logic
• Ensure accurate assignment of services to the appropriate NPI
• Maintain ongoing enrollment and compliance documentation

These activities would involve coordination across enrollment, billing, compliance, and finance functions.

Revenue Cycle Considerations

From a revenue cycle standpoint, the introduction of additional NPIs could affect:

• Claim submission workflows
• Payment attribution and reconciliation
• Denial management related to enrollment or identifier mismatches
• Internal controls supporting billing accuracy

Hospitals would need to ensure that systems and processes support consistent identification of off-campus services under the appropriate NPI.

Planning Considerations

While the legislation remains under consideration, healthcare finance and revenue cycle leaders may wish to:

• Review how off-campus departments are currently enrolled and billed
• Identify systems that rely on NPI-based logic
• Assess current controls related to site-of-care reporting and attribution

Understanding the differences between current requirements and proposed changes can support operational planning and readiness.