On May 12, the Children's Hospital Association sent a letter urging CMS to exempt children's hospitals with minimal Medicare utilization from the new off-campus outpatient department National Provider Identification and attestation requirements established in the Consolidation Appropriations Act of 2026.
The letter emphasizes that children's hospitals have a very limited Medicare footprint, and these requirements would impose significant administrative, billing, and operational burden with little corresponding Medicare program benefit. We also raise concerns that these requirements could disrupt care coordination, make it harder for children's hospitals to sustain and expand community-based outpatient specialty services, and potentially lay the groundwork for broader policies that could further threaten access to specialized pediatric outpatient care, particularly in rural and underserved communities.
