Medicare Mandates Unique IDs for Off-Campus Clinics: Hospitals Must Prove Compliance by 2026

The Fair Billing Act is setting up new rules for how hospitals get paid by Medicare for services delivered at their off-campus outpatient departments—think of that urgent care center or specialty clinic run by the hospital system but located miles away from the main campus.

The New Paperwork Trail

Starting January 1, 2026, these off-campus clinics can’t bill Medicare unless they have their own unique health identification number. This number must be separate from the main hospital’s ID. Essentially, Uncle Sam wants to track these remote locations individually, making it harder for services to get lost under the umbrella of the main hospital.

On top of the new ID requirement, the main hospital needs to submit an attestation—a formal statement—to the Secretary of Health and Human Services (HHS) proving that the off-campus department is following all the relevant federal rules (specifically, 42 CFR 413.65). This isn't a one-and-done deal. Hospitals must submit an initial attestation within the two years leading up to the 2026 deadline, and then submit follow-up attestations whenever the Secretary asks for them. If the ID is missing or the attestation is out of date, Medicare won't pay for the services.

What This Means for Hospitals and Patients

For the massive hospital systems running these clinics, this means a significant administrative lift. They have to manage a new set of unique IDs and a continuous cycle of compliance paperwork. If you work in healthcare administration or billing, this is a major change to your workflow. The bill gives the Secretary one year to set up the formal process for submitting these attestations and verifying compliance—including site visits or remote audits. The entire system hinges on HHS getting this process right and rolling it out smoothly.

This increased scrutiny aims to improve transparency and accountability in Medicare billing. When hospitals have numerous off-campus locations, it can be tough to track exactly where services are being delivered and whether those locations meet all regulatory standards. For patients, better oversight should translate into more accurate billing and higher quality of care, especially if the audits ensure these remote sites are up to code.

The Catch: High Stakes and Broad Authority

Here’s the part that needs attention: The stakes are incredibly high for hospitals. If an off-campus department fails to secure that unique ID or keep its attestation current by the 2026 deadline, Medicare payments for that entire location stop cold. No payment means that clinic either has to scramble to fix the issue or potentially shut down services, which could affect access for people who rely on that convenient local clinic.

Furthermore, the bill gives HHS broad authority to request follow-up attestations “whenever the Secretary tells them to.” While the goal is compliance, this open-ended requirement could lead to significant and unpredictable administrative burdens for hospitals, potentially diverting resources away from patient care and into paperwork. The Inspector General is tasked with reviewing this entire verification system by 2030, but in the meantime, hospitals will be navigating a new, high-stakes compliance environment.