Traditional MedicareCoverageHigh impact
2026-08-13 - CMS Announces Resources, Flexibilities to Assist with Public Health Emergency in State of Washington
Medicare/CMS·WA·General
Effective date
Jan 1, 2028
We identified it
Aug 13, 2026
Summary
This MLN Connects newsletter (dated August 13, 2026) announces multiple Medicare policy updates effective in FY 2027 and beyond, including new off-campus outpatient department requirements, updated payment rates for SNF and IRF, and a new RAPID device coverage pathway. Most significantly, off-campus outpatient departments must obtain separate NPIs and submit attestations by January 1, 2028, to continue receiving Medicare payment.
Action Required
REQUIREMENTS:
1. By August 31, 2026 (COMMENT DEADLINE): Billing leadership should review the CY 2027 Hospital Outpatient Prospective Payment System proposed rule at regulations.gov and submit comments if your practice operates off-campus outpatient departments.
2. By January 1, 2028 (COMPLIANCE DEADLINE): For each off-campus outpatient department of a provider:
- Billing team and compliance staff must obtain a separate NPI for each off-campus department and configure billing system to use correct NPIs
- Providers/medical directors must submit initial attestation demonstrating compliance with provider-based regulations within the prior 2 years to CMS
- Update billing workflows to ensure all claims from off-campus departments bill under the separate NPI
- Establish process for subsequent attestations at CMS-specified intervals
CONSEQUENCE: Claims submitted from off-campus outpatient departments without proper NPI and attestation will be denied by Medicare effective January 1, 2028.
3. Immediately: SNF and IRF billing teams should download updated FY 2027 pricers (effective October 1, 2026) and update billing software wage index calculations. Note the permanent 5% wage index decrease cap applies (except for new SNFs).
4. For Washington state facilities affected by wildfires: Contact CMS Emergency Preparedness & Response Operations webpage for available waivers and flexibilities to ensure uninterrupted claims processing.