On February 2, 2011, the Centers for Medicare and Medicaid Services (“CMS”) issued its final rule regarding the new provider and supplier enrollment screening criteria for Medicare, Medicaid and Children’s Health Insurance Program (“CHIP”) pursuant to Section 6401(a) of the Patient Protection and Affordable Care Act (“PPACA”). Included in the new enrollment processes is a requirement that providers and suppliers revalidate their enrollment pursuant to the new screening criteria. For a more detailed explanation of Medicare enrollment, including the new rule, please click here.
On August 10, 2011, CMS issued an MLN Matters article reminding providers and suppliers of the new revalidation requirements. The new revalidation rules apply only to those providers and suppliers enrolled in Medicare, Medicaid or CHIP prior to March 25, 2011. Providers and suppliers affected by the revalidation rule should await notices from the Medicare Administrative Contractors (“MACs”) and then, within 60 days from the date of the notice, submit their revalidation. When notifications from their MACs to revalidate enrollment are received, CMS recommends providers and suppliers take the following steps:
- Update enrollment through the Internet-based Provider Enrollment, Chain and Ownership System (“PECOS”) or complete the appropriate 855 application;
- Sign the certification statement on the application;
- If applicable, pay any fees through www.pay.gov;* and
- Mail any supporting documents (e.g., proof of payment, if payment is made online) and the certification statement to the applicable MAC.
Failure to revalidate enrollment within the 60-day window may result in deactivation of a provider or supplier’s billing privileges. Revalidation notices will be sent to providers and suppliers until March 23, 2013.
* Note: CMS does not require online payment; payments may also be made using an electronic check, debit, or credit card.
For more information regarding provider enrollment and revalidation, please contact Daniel B. Brown, Esq. at (770) 804.4700, or Adrienne Dresevic, Esq. or Carey F. Kalmowitz, Esq. at (248) 996-8510 or (212) 734-0128 or visit the HLP website.