Resource Library: Results | Outpatient Facility Fee Reform: A 50-State Review

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A Crucial Step Toward Site-Neutral Payment: National Provider Identifier Reform

Authors: Jared Perkins, Roslyn Murray, Christopher M Whaley, and Erin C Fuse Brown
Date: 3/1/2026
Resource Type: Gray literature
The article argues that a new unique National Provider Identifier requirement for all off-campus hospital outpatient departments billing under Medicare increases transparency into billing practices and is needed for broader site-neutral reform.
Details
Publisher/Organization: Center for Advancing Health Policy through Research
Payer: Medicare
Summary: The article argues that a new unique National Provider Identifier (NPI) requirement for off-campus hospital outpatient departments billing under Medicare represents a critical first step for full site-neutral payment reform. The authors argue that the NPI requirement sheds light on hospital billing practices and could help inform efforts to prohibit or curtail anticompetitive practices. While the NPI requirement alone will not end site-based payment disparities, it creates the transparency needed to implement broader reforms.
Funding Disclosure: The authors did not disclose funding for this work.
Topic Areas: Policy Reforms, Site-Neutrality, Billing Transparency
Citation: Perkins J, Murray R, Whaley CM, Fuse Brown EC. A Crucial Step Toward Site-Neutral Payment: National Provider Identifier Reform. Health Affairs Forefront; March 25, 2026. doi:10.1377/forefront.20260323.245202

Unique National Provider Identifiers and a Push for Transparency

Authors: Christine H Monahan
Date: 3/1/2026
Resource Type: Gray literature
The article explains that requiring unique National Provider Identifiers for off-campus hospital outpatient departments could improve transparency and support site-neutral payment reform, but additional action is needed to maximize its impact.
Details
Publisher/Organization: Center on Health Insurance Reforms
Payer: Medicare
Summary: The article examines a 2026 federal law requiring hospitals to use unique National Provider Identifiers (NPIs) for each off-campus hospital outpatient department paid under Medicare. Current billing practices often obscure site of care, limiting the ability of state and federal regulators to enforce facility fee restrictions or implement site-neutral payment policies. The law aims to increase the accuracy of outpatient claims data and transparency on where care is delivered. The authors argue that additional action—such as requiring use of unique NPIs across all payers and improving data systems linking provider locations to parent organizations—would increase the impact of the new policy to the commercial market.
Funding Disclosure: West Health provided funding for this work.
Topic Areas: Policy Reforms, Facility Fees, Billing Transparency
Citation: Monahan CH. Unique National Provider Identifiers And A Push For Transparency. Health Affairs Forefront; March 25, 2026. doi:10.1377/forefront.20260324.115604

Outpatient Outrage 2026: Hospital Prices for Care Outside of Hospitals

Authors: Noah Austin, Manasvi Reddy, and Patricia Kelmar
Date: 1/1/2026
Resource Type: Gray literature
The report documents how facility fees for outpatient care in the commercial market have become increasingly prevalent as hospitals acquire physician practices, raising costs with few patient benefits.
Details
Publisher/Organization: U.S. Public Interest Research Group
Payer: Commercial Insurance
Summary: This report analyzes the growing use of facility fees for hospital outpatient care in the commercial market. It shows that they are applied in settings without hospital-specific resources and can substantially increase charges for preventive care, diagnostic tests, and routine visits without improving quality. These fees raise out-of-pocket costs and insurance premiums. The report highlights how integration has increased physician employment by hospitals, making it harder for patients to avoid settings with facility fees. The report also reviews state legislative actions and proposes policies such as site-neutral payments, unique National Provider Identifiers, facility fee bans for routine outpatient services, and public reporting of facility fee charges and payments.
Funding Disclosure: The authors did not disclose funding for this work.
Topic Areas: Facility Fees, Site-Neutrality, Vertical Integration, Policy Reforms, Billing Transparency
Citation: Austin N, Reddy M, Kelmar P. Outpatient Outrage 2026: Hospital Prices for Care Outside Hospitals. U.S. PIRG Education Fund; January 29, 2026. https://publicinterestnetwork.org/wp-content/uploads/2026/01/USPIRG-Outpatient-Outrage-2026-Report-Jan-29-2026.pdf.
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