Natlawreview iconNatlawreviewAug 28, 2026 ~1 min source read

More Than a Billing Requirement: CMS Turns Medicare Enrollment into a Program-Integrity Tool

The OPPS proposed rule would also codify and implement statutory enrollment and provider-based attestation requirements for certain off-campus hospital outpatient departments. If finalized, enrollment deficiencies historically treated as administrative could carry broader implications for billing privileges, repayment exposure and future participation in Medicare.

More Than a Billing Requirement: CMS Turns Medicare Enrollment into a Program-Integrity Tool

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The OPPS proposed rule would also codify and implement statutory enrollment and provider-based attestation requirements for certain off-campus hospital outpatient departments.

Next Steps Providers and suppliers should consider reviewing their Medicare enrollment processes now, paying particular attention to enrollment data, enrollment-change reporting procedures, management...

If finalized, enrollment deficiencies historically treated as administrative could carry broader implications for billing privileges, repayment exposure and future participation in Medicare.

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The OPPS proposed rule would also codify and implement statutory enrollment and provider-based attestation requirements for certain off-campus hospital outpatient departments. If finalized, enrollment deficiencies historically treated as administrative could carry broader implications for billing privileges, repayment exposure and future participation in Medicare. Organizations should coordinate enrollment and revenue-cycle functions with legal, compliance, enrollment, operations and billing personnel.

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  • Next Steps Providers and suppliers should consider reviewing their Medicare enrollment processes now, paying particular attention to enrollment data, enrollment-change reporting procedures, management...

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2 The proposals would significantly expand CMS's denial and revocation authority for program-integrity risks involving provider ownership and management, criminal and administrative actions, payment suspensions, business and financial relationships and shared locations.

Details worth keeping

Key Updates CMS has proposed a significant expansion of its Medicare provider enrollment and program-integrity authorities through the Calendar Year 2027 Home Health Prospective Payment System proposed rule (HH PPS) 1 and the Calendar Year 2027 Hospital Outpatient Prospective Payment System proposed rule (OPPS). Hospitals should also take inventory of off-campus HOPDs.

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