Meet the 2028 HOPD Attestation Deadline with Confidence.
Comprehensive compliance for hospital outpatient departments. We extract your documentation, identify your gaps, and deliver MAC-ready attestation packages. You approve and submit.
75%+
of hospitals sampled by the OIG had at least one off-campus site that failed a provider-based requirement.
24 yrs
Since CMS last required attestation
$20M
Federal funding for enforcement
The first mandatory HOPD attestation cycle in a generation.
The Consolidated Appropriations Act of 2026 eliminated the option to stay quiet. Every off-campus HOPD must attest or lose OPPS billing eligibility.
No grandfather clause
The BBA 2015 "excepted" status no longer protects against the attestation and NPI requirements. Every off-campus HOPD must comply regardless of prior status.
Revenue at risk
OPPS reimburses 1.5x to 3x higher than the Physician Fee Schedule. A single high-volume location can lose $500K to $2M+ in annual facility fee revenue.
Separate NPI required
Each off-campus HOPD must obtain its own National Provider Identifier. This impacts 340B eligibility, Medicaid enrollment, and commercial contracts.
We do the work. You approve the result.
Privagent connects to your enterprise systems, extracts documentation, and delivers completed attestation packages. No consulting armies. No spreadsheet chaos.
Connect
We connect to your enterprise document repositories: SharePoint, shared drives, EHR, financial systems, and revenue cycle platforms through secure, read-only connectors.
Extract and classify
Agents crawl your connected systems, extract relevant documents, and classify them against all 15 regulatory requirements under 42 CFR 413.65.
Analyze gaps
A gap analysis engine scores each site across all seven compliance criteria. Cross-site pattern detection identifies systemic issues for organization-wide remediation.
Deliver
We assemble completed attestation packages with narrative sections, supporting exhibits, and cross-references. 200+ pages per site, ready for MAC submission.
Complete compliance engagement, not a consulting project.
Every initial engagement includes all six deliverables at a single per-site price.
Operational Compliance Audit
A site-by-site evaluation of how each off-campus location operates today, mapped against the seven provider-based criteria and the 15 regulatory requirements under 42 CFR 413.65.
Gap Analysis
A weighted scoring report that highlights where each site falls short, with severity ratings and prioritized remediation recommendations.
Remediation Plan
Step-by-step actions to close each identified gap, with owners, timelines, and the documentation artifacts needed to satisfy MAC review.
Attestation Package
A complete, MAC-ready attestation package per site — 200+ pages of narrative, supporting exhibits, and cross-references. Your team approves and submits.
NPI Strategy
A site-level National Provider Identifier roadmap that accounts for 340B eligibility, Medicaid enrollment, and commercial contracting impact.
Staff Training
Role-based training for compliance, finance, and operations leaders so your team can sustain provider-based status after attestation is complete.
Ongoing compliance monitoring.
The attestation is the starting line. CMS can audit at any time. The platform keeps you ready.
Periodic Operational Reviews
Recurring site-level reviews to confirm each location continues to operate within the seven provider-based criteria.
Documentation Maintenance
Active monitoring of the documentation set so policies, contracts, and exhibits stay aligned with current operations.
Regulatory Monitoring
Tracking of CMS rulemaking, MAC guidance, and OIG enforcement activity, with impact summaries delivered to your team.
Re-Attestation Preparation
Continuous package readiness so the next attestation cycle is a refresh, not a rebuild.
Technology-driven compliance, not hourly consulting.
Traditional firms charge $15K to $40K per site and rely on manual labor. Privagent delivers more at a lower cost with faster turnaround.
Know where you stand before the deadline hits.
Download our HOPD compliance guide and find out what the 2026 law means for your off-campus locations.
Download the Compliance Guide
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