CMS has posted a listing of providers and suppliers that have received enrollment revalidation requests under the Patient Protection and Affordable Care Act provision requiring all enrolled providers and suppliers to revalidate their enrollment information under new screening criteria.
Under Section 6401 (a) of the act, providers that enrolled prior to March 25, 2011 are required to revalidate when so instructed by their CMS contractors. Keep in mind that just because a provider has updated an address on its RAC website in order to ensure prompt delivery of RAC letters, this does not constitute an official notification to CMS of an address change, which must be reported on the appropriate 855 form within the proper timeframe.
The initial round of revalidation requests went out to 89,000 providers and suppliers, according to information provided by CMS representatives during an Oct. 27 provider outreach call. That number since has risen to 105,080 providers and suppliers.
More than 9,000 callers participated in the outreach call, and judging by the few who managed to get in the Q&A queue, they were frustrated by the handling of requests, confused about the notification process and notably perplexed by attempts to utilize the PECOS online system for revalidating enrollment. During the call CMS representatives provided the regulatory basis and citations for the revalidation process, as well as a spirited review of all the planned updates to the PECOS system that will be taking place during the next 12-15 months. Unfortunately, a handout that was promised the day before the phone call was not available, leaving much of the presentation wanting for lack of visuals to support the important nature of the content and the seriousness of the revalidation initiative.
The first wave of providers and suppliers received their notices in a brightly colored envelope intended to attract attention, according to CMS, which also noted that the selection was targeted toward those not currently having a record in the PECOS online system. CMS has provided a sample revalidation letter so that providers can begin to review and assemble documents. While the push is toward the PECOS system, the letter states that enrollment also may take place via the old-fashioned method: the applicable 855 form. Unfortunately, the upgrades designed to make PECOS more user-friendly will be of no benefit to the first wave of those revalidating, as the upgrades are being phased in incrementally.
Providers and suppliers must wait to submit revalidation only after being asked by their MAC to do so – so keep your eye out for the brightly colored envelope and make sure that your PECOS address is up to date. Alternatively, if you are not in PECOS ensure that you have notified CMS appropriately (via the 855) regarding any address changes
During the conference call’s Q&A session two callers unfortunately took a large portion of the allotted time. One provider was trying to explain the difficulties of revalidating a large group practice of radiologists who perform services and assign their numbers at multiple facilities. That provider finally was instructed to get in touch with CMS offline to review the situation. Another caller read a Litany of the Saints venting on her frustration with doing revalidations for her small medical practice – apparently CMS didn’t want to be rude, so officials let her vent away. A few more inquiries were voiced and the Q&A came to a close with more than 400 folks still in the queue. Couldn’t CMS have stayed on the line a bit longer? The agency offered providers an e-mail address to send questions, but within a week of the call CMS had to send out a notice via the MACs indicating that it gave the wrong e-mail address! And since the notice went out via the MACs, there was no guarantee that those on the call received the corrected e-mail address.
As if these missteps weren’t enough, CMS announced that revalidation, originally slated to be completed by March 23, 2013, now has been extended by two years to March 23, 2015. On Nov. 7 Noridian notified its listserve members that revalidation had been extended two years, while the same day NGS notified its listserve members that CMS had not extended revalidation, merely suggesting that it may be appropriate to delay and offering a link to Medlearn Matters article #SE1126 (which indicated that the revalidation cycle had been extended through 2015). No matter whom you believe, if you have a revalidation letter or have been mailed one as per the CMS list, you have from 60 days of the date marked on the letter to process your revalidation. If you are on the list and did not receive a colored envelope in the mail, CMS is instructing you to contract your contractor.
One good piece of information that might have been lost in this call was an update to providers that they need not complete certain new data elements on either the paper or Internet-based PECOS versions of the CMS-855A application under Sections 5 and 6. The handout that was missing in action, appearing below, would have been a great aide in this regard:
Section 5 OWNERSHIP INTEREST AND/OR MANAGING CONTROL INFORMATION (ORGANIZATONS)
1.“Exact percentage of operational/managerial control this organization has in the provider”
Section 6 OWNERSHIP INTEREST AND/OR MANAGING CONTROL INFORMATION (INDIVIDUALS)
1.“Exact percentage of control as an Officer this individual has in the provider”
2.“Exact percentage of control as a Director this individual has in the provider”
3.“Exact percentage of management control this individual has in the provider” (under the “W-2 Managing Employee” heading)
4.“Exact percentage of this contracted managing employee’s control in the provider”
5.“Exact percentage of operational/managerial control this individual has in the provider”
In addition, under the "other ownership or control/interest" headings in Sections 5 and 6, the “exact percentage of ownership or control/interest” data element need not be completed if the organization/individual in question does not have any ownership, partnership, mortgage, security or other quantifiable interest in the provider.
For those providers and suppliers that submitted their enrollment applications to CMS on or after March 25, 2011, they will not be required to revalidate under this current initiative. Between now and March 23, 2015 MACs will send out notices on a regular basis to begin the revalidation process for each provider and supplier.
42 CFR 424.515 (d) provides CMS the authority to conduct these off-cycle revalidations, and further information regarding Medicare enrollment and the timelines associated with mandatory reporting of various items can be found in Chapter 10 of the Medicare Program Integrity Manual.
About the Author
Nancy Beckley is the president and CEO of Nancy Beckley & Associates. Nancy is certified in healthcare compliance by the Healthcare Compliance Board, and serves on the Part A and Part B Provider Outreach Education and Advisory Panel for First Coast Services Options (Florida Medicare). She previously served on the CMS Professional Expert Technical Panel for Comprehensive Outpatient Rehabilitation Facilities.
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