Home Health & Hospice Week

Don't let these new Medicare provider requirements catch you by surprise.

If you bill Medicare, it's time to get a strong handle on Medicare's "revalidation process." Not being in compliance means you're risking your carrier or intermediary putting the kibosh on your billing privileges.

Background: All Medicare providers must revalidate their Medicare information on file, via a CMS-855 form, within 60 days of receiving a written revalidation request from their Medicare intermediary or carrier, points out attorney Lyndean Brick, senior vice president of Murer Consultants Inc. in Joliet, IL. The Centers for Medicare & Medicaid Services handed down the requirement in the April 21, 2006 Federal Register.

"If you are enrolled in Medicare, but have not submitted a CMS-855 since 2003, you are required to submit a complete application," CMS says on its provider enrollment Web site. "Providers and suppliers should follow the instructions for completing an initial enrollment application."

Durable medical equipment suppliers have even less time to respond--30 days, CMS notes on the enrollment Web site.

Sounds simple enough, but many providers have never filed a complete CMS-855, which can make the revalidation process quite difficult, Brick warns. And you may even receive an onsite survey if CMS discovers enough discrepancies.

But that's not all. "Generally speaking, once a provider submits a complete CMS-855, either in response to a revalidation request or otherwise, the provider must then revalidate his or her entire CMS-855 filing once every five years--or within 90 days after any change in his or her Medicare provider information," Brick says. New Form Nixes NPI Notification Since CMS began requiring such reenrollments and issued revised 855 forms in 2006, providers have been giving the agency an earful about the headaches involved. CMS issued another 855 re-vamp in March, it says in a recent MLN Matters article (SE 8010).

"CMS incorporated a number of enhancements and changes ... to clarify the enrollment process and to reduce the burden imposed on the provider and supplier communities," the agency says in the article.

For instance: CMS rescinded its requirement to submit the National Provider Identifier number notification received from NPPES with the form.

Deadline: Contractors will accept the 2006 version of the 855 form through June, CMS says. However, "providers and suppliers should begin to use the new Medicare enrollment applications immediately," the feds urge.

The new reenrollment push isn't just affecting providers in fraud demonstration areas in California, Texas and Florida. "We submitted a CMS-855A to request a change in a managing employee," one home health agency told intermediary Cahaba GBA. "We received an information request letter from Cahaba stating that we must complete the entire application," the agency said, according to a recent Cahaba provider bulletin. "Why does the full application need to be completed when the [...]