Industry Insights

CMS Releases Important Provider Enrollment Updates & Changes

December 2016
Author:  Bob Lane

Bob Lane

Director

Consulting

Health Care

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The Centers for Medicare & Medicaid Services (CMS) recently released several notices pertaining to compliance and provider enrollment that could affect providers and practitioners.

In a Survey and Certification 16-37-ALL letter issued September 2, 2016, CMS modified the process providers undergoing initial enrollments or changes of ownership (CHOW) use to confirm their compliance with Office of Civil Rights (OCR) requirements. The new process requires Medicare Part A providers to sign an attestation of their compliance with all applicable civil rights laws enforced by OCR—including Title VI of the Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973, Title IX of the Education Amendments of 1972, the Age Discrimination Act of 1975 and Section 1557 of the Patient Protection and Affordable Care Act. This attestation is referred to as an Assurance of Compliance, and it’s on the U.S. Department of Health & Human Services website. New Medicare funding applicants and current providers undergoing a CHOW will be responsible for electronically submitting this attestation to the OCR through the Assurance of Compliance portal. The provider will receive electronic verification from OCR upon successful attestation submission.

Another compliance item involves the reporting of CHOWs. The CMS Medicare Learning Network Matters article issued September 22, 2016, SE1617, reminds providers and practitioners of the necessity to report ownership or practice location changes and adverse legal actions within 30 days of the change. All other changes pertaining to the provider or practitioner’s enrollment record must be reported to the Medicare Administrative Contractor (MAC) within 90 days of the change, in accordance with 42 Code of Federal Regulations (CFR) Section 424.516(d).  

If you’re a supplier of durable medical equipment, prosthetics, orthotics and supplies, you must report any information supplied changes on the enrollment application within 30 days of the change to the National Supplier Clearinghouse, per 42 CFR §424.57(c)(2).

Independent diagnostic testing facilities must report changes of ownership, location or general supervision changes and adverse legal actions to their MAC online or via the CMS-855 Medicare Enrollment Application within 30 calendar days of the change. Organizations must report all other enrollment information changes within 90 days of the change, per 42 CFR §410.33(g)(2).

All providers and suppliers not previously identified must report any CHOWs, including a change in an authorized or delegated official, within 30 days and all other informational changes within 90 days, per 42 CFR §424.516(e).

It’s important to comply with these reporting requirements. Failure could result in Medicare billing privilege revocation.

Lastly, CMS announced a revision of the CMS-855R Reassignment of Medicare Benefits application, which is completed by practitioners desiring to reassign Medicare benefits to an eligible organization/group to submit claims and receive payment for Medicare Part B services on their behalf. Physicians and nonphysician practitioners must use the revised CMS-855R application beginning January 1, 2017. MACs will accept the current and revised versions of CMS-855R through December 31, 2016. The revised form makes the primary practice location section optional. However, this information is shared with other programs, such as the Physician Compare Initiative, to help beneficiaries identify practices.

Visit the Medicare Provider-Supplier Enrollment website for more information about Medicare enrollment or contact your BKD advisor.

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