• CMS is Revalidating Enrollment Information of Particpating Providers and Suppliers
  • March 26, 2012 | Authors: Mark A. Borreliz; Kathleen Gleason Healy; Jeffrey L. Heidt; Tara Shuman; William H. Stiles; Brett D. Witham
  • Law Firms: Verrill Dana LLP - Boston Office ; Verrill Dana LLP - Portland Office ; Verrill Dana LLP - Boston Office ; Verrill Dana LLP - Portland Office
  • If it has not already happened, you can expect to receive an enrollment revalidation request from the Centers for Medicare & Medicaid Services (CMS) within the next three years. When the request is received, it is important that you respond promptly.

    The Affordable Care Act requires CMS to revalidate the enrollment information of all providers and suppliers under new, enhanced screening criteria in order to minimize fraud and abuse in the Medicare program. Most providers and suppliers will be asked to revalidate their information every five years, while certain suppliers, such as those providing durable medical equipment, prosthetic and orthotic supplies, and other services and supplies that CMS considers to be at higher risk of wrongful payment, will have their enrollment information revalidated every three years. By March 23, 2015, Medicare Administrative Contractors (“MACs”) will send out revalidation notices on an intermittent but regular basis for those providers and suppliers who were enrolled prior to March 25, 2011. Providers and suppliers must wait until being contacted by their MAC to submit the revalidation materials. CMS also currently is undertaking an “off-cycle”
    revalidation process for most providers, which means that a provider or supplier may be asked to revalidate their enrollment sooner than three or five years.

    When contacted by their MAC to revalidate the enrollment information, providers and suppliers may respond by using the internet-based Provider Enrollment, Chain, and Ownership System (PECOS), or by paper by completing the appropriate CMS-855 Medicare enrollment application. Responses to the revalidation requests must be submitted within 60 days, although a one-time 60-day extension may be requested. Failure to submit the enrollment forms may result in the deactivation of Medicare billing privileges.

    The Affordable Care Act requires that an application fee be imposed on revalidation for each institutional provider, which is defined as all providers except physicians, non-physician practitioners (NPPs), physician group practices, and NPP group practices. The fee for 2012 is $523.

    It is important to note that all mandatory reporting to CMS must continue even in the absence of a revalidation request. Physicians, NPPs, and physician and NPP organizations must report a change of ownership, any adverse legal action, or a change of practice location to the MAC within 30 days. All other changes must be reported within 90 days. Other providers and suppliers must report changes of ownership or control, including changes in authorized officials, within 30 days, and all other changes within 90 days.