Did you know that virtually all Medicare-enrolled providers and suppliers will be required to re-enroll with Medicare in the next 18 months? A little-noticed provision in the recent health care reform law requires CMS to revalidate the enrollment information for all Medicare-enrolled providers and suppliers enrolled before March 25, 2011 under new, stricter screening criteria as part of a new CMS anti-fraud effort.

The Medicare Administrative Contractors (MACs) will be mailing re-enrollment notices to each affected provider and supplier between now and March 23, 2013 on a regular basis. Affected providers and suppliers will have 60 days from the date of the letter to submit complete enrollment forms. Providers and suppliers must wait until they receive the letter from the MAC to submit their revalidation information. CMS states that using PECOS is the most efficient way to submit revalidation information; however, the certification statement, along with all required documentation, must be printed, signed and mailed to the MAC once completed. CMS has stated that it hopes to upgrade its enrollment website to permit electronic signatures by January 2012, but that process has not yet been completed.

All “institutional providers” must also pay a $505.00 application fee. “Institutional provider” means any provider or supplier submitting a Form 855A, 855B or 855S, but does not include physician or non-physician practitioners.

The new screening criteria are intended to reduce Medicare fraud. Physicians and non-physician practitioners are considered “limited-risk” and will be subject to less stringent criteria. Other types of providers and suppliers are considered either “moderate risk” (e.g., physical therapists, x-ray suppliers and currently enrolled home health agencies) or “high risk” (new home health agencies and new equipment suppliers) and will be subject to stricter criteria.

This is causing a great deal of angst among providers and suppliers who are worried about the potential of a re-enrollment backlog and the possibility of delayed reimbursements. Please contact our Health Care Practice Group if you have any questions regarding this matter.

The CMS notice regarding the revalidation effort can be found here.

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