August 29, 2011
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Health Law Alert: CMS Announces New Medicare Enrollment Revalidation Initiative, Issues Revised Enrollment Applications
CMS announced recently that it will require all providers and suppliers enrolled in Medicare before March 25, 2011, to reconfirm the accuracy of their enrollment, a process known as “revalidation.” The only category of providers and suppliers that are exempt are those who enrolled in Medicare after March 25, 2011.
Many providers may remember the massive revalidation initiative that occurred in 2009, and in particular some of the challenges that were part of that process. For several reasons, CMS’ earlier initiatives caught providers off-guard. Revalidation requests were not sent via certified mail, which in some cases led to requests being lost in the everyday shuffle of correspondence. Some requests were addressed to practice locations on file with CMS that did not receive mail (because the provider receives mail at a separate address). There was also confusion about how revalidation requirements interact with obligations to report changes of information—like changes in practice locations—to CMS within specified time periods. Some providers fell into the trap of thinking that revalidation allowed them to wait to inform CMS all at once of changes, when in fact they were obligated to inform the agency within 30 days of the change.
In its new initiative, CMS will contact providers and require complete enrollment applications and supporting documents to be provided to the agency within 60 days. Failure to respond within this timeframe can lead to loss of billing privileges for one year, effective just 30 days after CMS mails notice of its determination. Although an appeals process exists, there is no guarantee that a provider will succeed in reversing CMS’ decision. Thus, quick action in response to a revalidation request is imperative. Some providers might prefer to proactively revalidate—with the goal of taking care of this obligation while it is fresh in mind, as opposed to waiting to receive CMS’ request. Unfortunately, this will not be permitted. Instead, providers and suppliers must wait to receive a request from CMS.
CMS Announces New Medicare Enrollment Forms
Why Did CMS Revise the Enrollment Forms?
Changes to the CMS 855 Forms
The 855A was also revised to enact new restrictions made under the Act to the Stark Law’s exception for physician ownership in hospitals. Section 2 of Form 855A now requires the applicant to indicate whether it is a physician-owned hospital. If so, the hospital is required to complete the new Attachment 1, which consists of two sections. Section 1 of the Attachment must be completed for every organization that has any percentage of ownership or investment interest in the physician-owned hospital. Similarly, Section 2 must be completed for every individual that has any percentage of ownership or investment interest in the physician-owned hospital.
855B, 855S, and 855I
Transitioning to the Revised Forms
If you have questions on CMS’ new revalidation initiative or the new CMS-855 forms, please contact Jesse Berg at firstname.lastname@example.org or 612.632.3374.
This article is provided for general informational purposes only and should not be construed as legal advice or legal opinion on any specific facts or circumstances. You are urged to consult a lawyer concerning any specific legal questions you may have.
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