Ann & Natalie’s Compliance Corner
Welcome back to Ann & Natalie's Compliance Corner! This month, we discuss the Centers for Medicare and Medicaid Services’ (CMS) recent enforcement of Medicare enrollment regulations. Missed last month’s guidance on updating your compliance plan in response to the 2008 Work Plan of the Office of the Inspector General (OIG)? Click here.
In April 2006, CMS issued new regulations regarding enrollment and verification. The new regulations, which CMS is now implementing on a rolling five-year schedule, require healthcare suppliers and providers to revalidate their participation in the Medicare and Medicaid programs. CMS recently began the revalidation process by requiring Medicare contractors to mail revalidation requests to their top regional billing providers and suppliers before the end of September 2007.
Through the revalidation plan, CMS intends to ensure that Medicare has current, accurate information on providers and suppliers, and to evaluate providers’ and suppliers’ compliance with Medicare enrollment requirements and regulations. CMS may conduct on-site audits of any provider or supplier to verify the accuracy of information submitted during the initial enrollment or revalidation.
Providers who received revalidation letters from CMS must complete the appropriate application: Form 855A for institutional providers, such as hospitals and nursing facilities, and Form 855B for most physician group practices and clinics. Your practice must submit the applications to your Medicare contractor within 60 days of the postmark date on the letter. Some practices that have submitted a complete 855 application within the past 12 months may not be required to submit new forms.
However, if your practice submitted only a partial application to report a change of information, you will be required to submit a complete application for revalidation. If you receive a revalidation letter from a Medicare contractor, and if you believe you submitted a complete Form 855 within the past 12 months, you should notify the Medicare contractor and submit a copy of the letter confirming the date the application was complete. If you do not receive written confirmation of exemption before the deadline, you should be prepared to comply with the revalidation request. Failure to comply with the revalidation process within the required timeframe may result in the revocation of your enrollment and billing privileges.
Form 855 is complex, containing 42 pages. In order to complete the form, you must collect detailed, historical information from various departments and individuals within your practice. You should bear in mind that your Medicare contractor will validate the accuracy of all information submitted on the form. If the Medicare contractor does not find a match, he or she will contact you for clarification. You are also required to submit all supporting documentation with the CMS 855. Initial submissions should ideally be as accurate as possible in order to avoid additional scrutiny later.
After you submit the CMS 855, your mandatory five-year revalidation cycle begins. Going forward, you must report a change of information supplied on the 855 application within 90 days. You also must report a change of ownership or control of a provider or supplier within 30 days. The failure to promptly report these changes may result in the revocation of your practice’s Medicare enrollment and billing privileges.
For more information on the CMS revalidation plan, please click here: http://www.cms.hhs.gov/cmsforms/downloads/cms855i.pdf
The regulation may be found at: 42 C.F.R. § 424.515
Disclaimer: The content of Compliance Corner is for general informational purposes only and should not be interpreted as compliance guidance or advice. Consult your compliance advisor or attorney for compliance or legal advice on specific issues related to your practice or compliance program.
