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Tips for New Enrollment & Revalidation for Participation in Medicare & Medicaid

The new enrollment and revalidation requirements for providers and suppliers for Medicare/Medicaid participation was previously  detailed on this blog. As promised as a follow-up, this blog post will describe enrollment best practices and tips for ensuring that enrollment or revalidation is properly accomplished. Not only is initial enrollment now more onerous, but revalidation is required for all physicians and other providers/suppliers who were enrolled before March 25, 2011, which generally means that all physicians and physician groups must complete the re-enrollment process. A failure to re-enroll means that CMS will de-activate payment until a successful re-enrollment process is completed. In some cases, CMS may even revoke participation. Thus, it is crucial that physicians, providers, and suppliers get it right the first time.

First things, first: watch the mail! Staff should be counseled about where to direct revalidation requests for prompt attention to avoid deactivation based on a failure to respond to a MAC request. Providers and suppliers should check the CMS website to see if a revalidation request has been sent.

Next, do not forget the application fee. For CY 2014, the fee is $542.00 for institutional providers and this must be paid in the event of initial enrollment, revalidation, or the addition of a practice location. Always submit an application fee receipt.

Many completing the forms may be tempted to use the online Provider Enrollment, Chain and Organization System (“PECOS”). The system can be used for an initial enrollment application, to change enrollment information, and to submit changes to an existing enrollment record, among other things. While the system allows for faster completion and processing, the system is still under development which means that electronic submission is complicated. Because inaccurate applications can result in rejection, we recommend that enrollees submit an re-enrollment application using the paper form. At a minimum, all information should be verified before it is entered into PECOS, as there have been many issues with correcting inaccurate information once it has been submitted.

Before the form leaves the office, an appointed person should check all of the following:

  • Is the form version correct?
  • Is the address correctly reported?
  • Is the application dated?
  • Are the signatures dated?
  • Is all the requested information complete and accurate?
  • Is the correct National Provider Identifier used?
  • Does the mailing have the correct postage amount?

All physicians, providers, and suppliers must adjust how we think about enrollment. Enrollment is no longer a one-time application; enrollment is an on-going process that requires vigilance, internal policies and procedures and a devoted team that can commit time and attention necessary to the forms. McBrayer health care attorneys can be a part of your compliance team. If you need help with initial enrollment or revalidation, contact us today.

Lisa English Hinkle

Lisa English Hinkle is a Member of McBrayer, McGinnis, Leslie & Kirkland, PLLC.  Ms. Hinkle concentrates her practice area in health care law and is located in the firm’s Lexington office.  She can be reached at lhinkle@mmlk.com or at (859) 231-8780, ext. 1256. 

This article is intended as a summary of federal and state law and does not constitute legal advice.

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