Medicare tightens off-campus billing: separate IDs, compliance attestations required
S. 2497 — Fair Billing Act · Filed by Maggie Hassan (D-NH) · 1 cosponsor · Introduced Jul 29, 2025 · Referred to committee
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What it does
This bill requires off-campus outpatient departments of hospitals and medical providers to obtain a separate Medicare billing identifier and submit attestations that they comply with federal regulations governing provider-based departments. Starting January 1, 2026, Medicare will not pay for services from these off-campus departments unless they meet these new identification and compliance-verification requirements. The bill aims to prevent billing fraud and ensure off-campus departments are legitimately provider-based rather than independent facilities billing under a hospital's credentials.
Why we flagged it
The bill's operative mechanism is a payment condition tied to compliance verification and separate identification for off-campus departments. It is a regulatory enforcement and transparency measure, not a subsidy, carve-out, or deregulation.
What the text implies
- Hospitals with off-campus departments may face significant compliance costs and administrative burden to obtain separate identifiers and submit attestations, potentially delaying or complicating expansion of outpatient services.
- The Secretary has broad discretion to define the attestation process and compliance review methods (site visits, remote audits, etc.), creating potential for inconsistent enforcement across regions.
- Smaller or rural providers with limited off-campus operations may face disproportionate compliance costs relative to large health systems with established compliance infrastructure.
- The 2030 HHS OIG report requirement suggests Congress expects implementation challenges; early enforcement may reveal gaps in the attestation process or CMS's ability to verify compliance at scale.
Section numbers refer to the bill text the analysis read — linked under Primary records below.
Who it affects
Ordinary people benefit from reduced billing fraud and clearer accountability for off-campus departments that may have been improperly billing under hospital credentials. The compliance requirement and separate identifier create transparency and prevent cost-shifting. The administrative burden falls on providers, not patients.
Named in the bill
Centers for Medicare & Medicaid Services (CMS), Department of Health and Human Services (HHS), HHS Office of Inspector General (OIG), Hospitals and medical providers with off-campus outpatient departments, Medicare program
Where it stands
1 cosponsor: 1 Republicans.
- Jul 29, 2025 — Introduced · Congress.gov: “Introduced in Senate”
- Jul 29, 2025 — Referred to Senate Committee on Finance · Congress.gov: “Read twice and referred to the Committee on Finance”
Dates and quoted wording are Congress.gov's action record; the timeline shows status changes, not every procedural step.
Money around this bill
2 lobbying clients named this bill on 2 disclosure filings across 2 quarters, Dec 2025 to Jun 2026. Those filings disclosed $944,000 in lobbying spend. A filing names 14 bills on average, so that figure is what each filing reported, not a share belonging to this bill.
More lobbying clients named this bill than 41% of bills with at least one filing.
Maggie Hassan, the sponsor, reported $636,785 in PAC receipts in the 2026 cycle.
- Health Care Service Corporation, a Mutual Legal Reserve Company (hcsc) — $730,000 on 1 filing
- American Benefits Council — $214,000 on 1 filing
Lobbying Disclosure Act filings through Jul 20, 2026. A filing shows who paid to lobby on a bill it names, not what changed.
How this was measured
Analysis — Quorum's AI read the bill text published by Congress.gov (3,016 characters) on Oct 31, 2026. Section numbers in the findings refer to that text, linked below; transparency and hidden-provision scores are compared against the median of 16,778 analysed bills.
Status and sponsors — Congress.gov's bill record — actions, committee referrals and cosponsors — loaded nightly. The timeline shows status changes, not every procedural action.
Money — Senate Lobbying Disclosure Act filings whose specific-issue field names this bill for quarters ending Dec 2025 to Jun 2026. A filing's amount is reported whole beside the median number of bills a filing names; it is never divided across them. PAC receipts are FEC-reported contributions to the sponsor's candidate committee in the 2026 cycle.
As of — lobbying records through Jul 20, 2026 · page rendered 2026-10-31.
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