July 31, 2015
By Clayton Gritz*
This Accreditation, Certification, and Enrollment (ACE) Blast is a legal alert brought to you by the ACE Affinity Group (AG). The ACE AG provides an organized forum for members to learn about legal developments and best practices relating to the ACE of health care providers and health care professionals.
CMS Announces Extension of Temporary Moratoria on Enrollment of Ambulance Suppliers and HHAs in Designated Geographic Locations
On July 28, the Centers for Medicare & Medicaid Services (CMS) announced a six-month extension of temporary moratoria on the Medicare, Medicaid, and Children’s Health Insurance Program enrollment of new ambulance suppliers and home health agencies (HHAs), subunits, and branch locations in select metropolitan areas in Florida, Illinois, Michigan, New Jersey, Pennsylvania, and Texas. The initial moratoria were issued on July 31, 2013 and encompassed certain metropolitan areas in Florida, Illinois, and Texas. The moratoria have since been extended and expanded to include metropolitan areas in Michigan, New Jersey, and Pennsylvania.
In determining whether to impose and subsequently extend the enrollment moratoria, CMS weighed qualitative and quantitative factors that suggested a high risk of fraud, waste, or abuse. CMS also relied on law enforcement’s experience with ongoing and emerging fraud trends. CMS has no concerns that the moratoria extensions will limit beneficiary access to HHAs and ground ambulance suppliers.
If CMS deems it necessary, the moratoria may be extended for additional six-month increments.
*We would like to thank Clayton R. Gritz (Stevens & Lee PC, King of Prussia, PA) for providing this email alert. We also would like to thank the Accreditation, Certification, and Enrollment Affinity Group leadership for sharing this email alert with the Children's Hospital Affinity Group, and the Academic Medical Centers and Teaching Hospitals, In-House Counsel, and Post-Acute and Long Term Services Practice Groups.