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When major health systems acquire off-campus clinics, they’ve historically been able to use their main hospital’s assigned 10-digit National Provider Identifier (NPI) number to bill Medicare for routine visits at the off-campus site, securing significantly higher facility-level reimbursements. But starting in 2028, a new bipartisan policy will require hospitals to use distinct NPIs when billing for Medicare services provided at their off-campus outpatient sites. This concept of “site-neutral payment” will impact urgent care centers, essentially leveling the playing field regardless of ownership. While it is not guaranteed that the law will change reimbursement in the commercial market, Medicare policies historically have a way of spilling over across all payer types one way or another.
“This upcoming NPI reform is a critical course correction,” says Alan A. Ayers, MBA, MAcc, President of Urgent Care Consultants and Senior Editor of JUCM. “By closing this billing loophole, we are finally moving toward true site-neutral payments. This doesn’t just equalize reimbursement between independent urgent care centers and massive hospital networks—it removes the financial incentive for hospitals to buy up independent practices purely for billing arbitrage. Ultimately, it fosters fair competition and ensures payment for the actual medical service provided rather than the corporate logo on the building.
”Cost effects: Transitioning to site-neutral payments could save Medicare billions, according to an analysis in Health Affairs. Estimates suggest it could save Medicare up to $153 billion, lower patient premiums by $94 billion, and save the commercial market $10.8 billion annually.