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Provider-Based Compliance / Reimbursement & Medicare Enrollment

Monday, October 5, 2026
2:00 PM - 2:45 PM
Zlotnik Ballroom

Overview

As physician practices continue to affiliate and align with hospital systems, the Consolidated Appropriations Act, enacted on February 3, 2026, has established new requirements for “provider-based” departments that present fresh challenges for providers. This session will provide an overview of the requirements for provider-based designation, why the designation matters for payment, coverage, billing, and compliance, including key policy shifts leading to the CAA 2026. The latest CMS updates and practical tips for compliance with the CAA 2026 requirements for off-campus departments—mandatory NPIs and attestations beginning January 1, 2028—will be covered in the presentation.


Darby Allen
Partner
Davis Wright Tremaine LLP

Speaker

Darby serves as the firmwide chair of Davis Wright Tremaine’s Healthcare Practice Group. She advises health systems and other providers, as well as innovators in the industry, on a wide spectrum of regulatory issues. She has extensive experience with the federal and state fraud and abuse laws. Darby also regularly assists clients with Medicare and Medicaid audit responses, payor disputes, day-to-day operational counseling, and reimbursement matters. She practiced in Houston for several years before moving to Seattle in 2017.
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Gregory Etzel
Partner
Morgan, Lewis & Bockius LLP

Speaker

Greg Etzel concentrates his practice on the representation of hospitals and other healthcare providers in a variety of complex legal transactions, regulatory litigation, and compliance advice. Greg has pursued administrative litigation on behalf of his clients from the earliest stages of a regulatory challenge through final decision in federal court on a variety of federal payor reimbursement and other agency disputes. Greg regularly advises healthcare clients on a multitude of billing and payment compliance matters arising out of federal healthcare programs. Prior to joining Morgan Lewis, Greg spent five years in-house as the vice president of legal affairs at the University of Texas Medical Branch (UTMB), providing legal counsel and representing the institution on a wide-range of matters, gaining a valuable perspective from the inside of a large academic medical center. Before his time at UTMB, he served as a partner in the Houston office of another global law firm, and has specialized in healthcare regulatory matters since his legal practice began in 1995.
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