(March 17, 2017): The Centers for Medicare and Medicaid Services (CMS) recently announced that it will be initiating its next round of CMS revalidation requests to all Medicare enrolled providers and suppliers. Current law and regulations require providers and suppliers to revalidate their enrollment with Medicare every five years (every three years for DME suppliers). There are a few changes being made to try and give providers a bit more flexibility this time around.
I. Highlights of the CMS Revalidation Initiative Beginning This Year:
- CMS will maintain a master list of providers/suppliers due for revalidation along with the due date for their applications here: https://data.cms.gov/revalidation. CMS has advised that all providers/suppliers should check this list to see when their application is due. If a due date is more than six months away, the list will show “TBD” for a provider/supplier due date. DO NOT SUBMIT A REVALIDATION APPLICATION IS NO DUE DATE APPEARS. IT WILL BE RETURNED.
- The website will also provide a list of all reassignments for those suppliers that maintain reassignments.
- Providers and suppliers don’t have to wait for a letter from their Medicare Administrative Contractor (“MAC”) to submit a revalidation application. If you are within six month of your due date shown on the above website, you are encouraged to submit your application.
- MACs will still send an email or letter to providers/suppliers 2-3 months prior to their due date asking them to revalidate. Emails will include the title “URGENT: Medicare Provider Enrollment Revalidation Request.” If emails are returned as undeliverable, a paper letter will be sent. All letters will be sent to at least two of a providers/suppliers reported addresses (e.g. a correspondence and special payments or primary practice location address.
- Revalidation notices sent to individual practitioners who have reassigned their billing rights to a group or groups will include a list of all reassignments on file with CMS. Special procedures will be available for groups with more than 200 members.
- An upcoming revalidation does not relieve providers/suppliers from submitting updates to their enrollment record in the timeframes required by relevant regulations. Submit all changes of information timely, even if a revalidation is due within the next six months.
II. Tipe for Ensuring Your CMS Revalidation Efforts Have Been Completed:
In addition to outlining the process for the next round of revalidation, CMS has provided tips for ensuring your revalidation is complete.
- Providers and suppliers are required to revalidate their entire Medicare enrollment record, including all practice locations where they see patients and all groups to which they reassign benefits.
- All of a provider’s or supplier’s NPIs and PTANs must be revalidated when revalidation is requested.
- Either PECOS or the paper CMS-855 applications may be used for revalidation.
- If a provider or supplier is deactivated for failing to submit a revalidation application on time or failing to respond to a request for additional information on a pending application, they may reactivate their enrollment by submitting a new, full application. The provider/supplier, once the application is processed and approved, will maintain their original PTAN, but the reactivation date will be whatever date the new, full application was submitted. Retroactive billing privileges back to the date of deactivation will not be granted and the provider/supplier will have gap period where they may not receive payment for services provided to Medicare beneficiaries.
- CMS has reminded certain providers and suppliers that a fee is due with their revalidation application. All “institutional providers” that submit an application via PECOS or a paper Medicare enrollment application using the CMS-855A, CMS-855B (except physician and non-physician practitioner organizations), or CMS-855S forms are required to pay the application fee. For Calendar Year 2017, the fee is $560. It can be paid via this website: https://pecos.cms.hhs.gov/pecos/feePaymentWelcome.do#headingLv1 Be sure to print proof of payment with your revalidation application to avoid delays in processing.
III. Other Important Considerations:
CMS also noted that all providers and suppliers that have not billed Medicare for 12 consecutive months will have their billing privileges deactivated. To reactivate their provider number, a complete, new application must be submitted. Once approved, the provider/suppliers will retain its original PTAN. The effective date of reactivation will not be retroactive to the date of deactivation.
We encourage all providers and suppliers to check CMS’ list of revalidations due in the upcoming six months. The list is updated every sixty days. If you choose to use PECOS to complete your revalidation, be sure to print a copy of your submission BEFORE you click the submit button. You need to retain a copy of what you submit indefinitely in order to substantiate what you input via PECOS. We have seen far too many providers and suppliers think they properly completed a revalidation application via PECOS only to be revoked later on because some data point was missing from a submission or was submitted under the incorrect enrollment file or field. Also:
- If you are a physician who is the sole shareholder of your practice, you do NOT need to complete a CMS-855B in most instances. However, it is very important to properly identify your practice locations under both your individual and your entity’s enrollment in PECOS when you revalidate those enrollments. Don’t make the mistake of thinking that listing practice locations under just your individual enrollment will make them automatically appear under your entity (or vice versa).
- Physicians and non-physician practitioners that reassign payments to groups must identify all groups to which they reassign on their revalidation. Failure to list a group may result in a reassignment being deactivated. You do not need to submit new CMS-855Rs with your revalidation.
- If you check the list of revalidations that are due and you can’t locate your record after searching by name or NPI…CALL YOUR MAC. The list contains all active Medicare program providers and suppliers, including DME suppliers. If you do not appear on the list, you need to find out why.
CMS has published an article discussing the revalidation process in more detail here: https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/downloads/SE1605.pdf In addition, you may visit this CMS website for additional information: https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/MedicareProviderSupEnroll/Revalidations.html
Liles Parker PLLC attorneys have extensive experience helping providers and suppliers navigate through the Medicare enrollment and revalidation process. Please contact us if you have questions or need assistance.
Jennifer Papapanagiotou, Esq is a health law attorney with the firm, Liles Parker, Attorneys & Counselors at Law. Liles Parker has offices in Washington DC, Houston TX, McAllen TX and Baton Rouge LA. Our attorneys represent dentists, orthodontists and other health care professionals around the country in connection with Medicare provider enrollment and revocation matters. Need assistance? For a free consultation, please call: 1 (800) 475-1906.