The question of whether a lodge has to be within park boundaries is actually part of a much larger question: What constitutes a National Park Lodge?
It would be nice if a series of rules could be applied, but very few lodges fit squarely in the definition of concessionaire operations within park boundaries. Moqui Lodge, for example, was located outside Grand Canyon NP, but during the 1970s its purpose and sense of community was such that it truly stretched the boundaries and became a national park lodge. White's City is a privately-owned sprawl outside the boundaries of Carlsbad Caverns NP that looks nothing like a traditional park lodge, but is nevertheless part of the park experience for many visitors. Other facilities might even use the name of a nearby park, exist only because of the park, yet are little more than road motels or cabin complexes with no significance.
As Congress once said of a much seedier topic, "we can't define it, but we know it when we see it." The definition of "park lodge" is thus subjective, but with your participation the NPLAS can continue to expand and provide accurate assessments.