March 8, 2016
By Gail Pabarue*
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.
On March 1, the Centers for Medicare & Medicaid Services (CMS) Division of Enrollment Operations conducted a national provider call and released information regarding Cycle 2 of the CMS provider and supplier revalidation process. CMS has completed its initial round of revalidations as required by the Affordable Care Act, and Cycle 2 will now resume the regular, periodic revalidation cycles in accordance with 42 CFR §424.515. All providers and suppliers enrolled currently in Medicare are required to resubmit and recertify the accuracy of enrollment information under new enrollment screening criteria every five years (durable medical equipment suppliers must revalidate every three years). In an effort to streamline the revalidation process and reduce provider and supplier burden, CMS has implemented a major revalidation process change: Due dates for revalidations will fall on the last day of a month and will generally remain the same for subsequent revalidation cycles. These due dates will be posted to a new CMS website, which also will have a lookup feature of providers and suppliers.
Providers and suppliers should continue to respond to requests from their Medicare Administrative Contractor (MAC) on a timely basis to avoid Medicare payment gaps or possible deactivation of billing privileges. Unlike previously, reinstatement of billing privileges after a deactivation will not be retroactive to the date of deactivation, but will only be retroactive to the date of submission of a subsequently approved new enrollment application, which would result in a gap in payments.
Providers and suppliers should not submit unsolicited revalidation applications. CMS has directed the MACs to return unsolicited applications in instances where a provider submits an application for revalidation more than six months in advance of its due date, when a due date is not listed on the CMS.gov list, and/or when the provider’s MAC has not sent a notice letter or email requesting revalidation materials.
Other Medicare provider and supplier actions, including change of ownership and change in practice location or reassignment, remain separate from the provider revalidation process. Providers should submit any such change to its CMS enrollment record via the Internet-based Provider Enrollment, Chain, and Ownership System or by submitting the appropriate CMS-855 form.
For additional detailed information, please see the Revalidations page of the CMS website and the Medicare Learning Network article regarding the Cycle 2 revalidations.
*We would like to thank Gail D. Pabarue (Henry Ford Health System, Office of the General Counsel - Health Alliance Plan Campus, Detroit, MI) 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 Post-Acute and Long Term Services Practice Group.