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For instance: CMS rescinded its requirement to submit the National Provider Identifier number notification received from NPPES with the form.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 administrator is the only change that took place?" the agency asked.

"CMS requires that all enrollment information from the CMS-855 application be input into the Provider Enrollment Chain and Ownership System (PECOS)," Cahaba explains in the Newsline. PE-COS record creation requires certain information that must be "verified to be current and correct," the intermediary says. "In order to determine this, the provider must submit the most current information via the CMS-855 application."

That all adds up to more burdensome paperwork for already stretched staff, providers complain.

Know What CMS Is Looking For

If you're not sure what kind of information you need to have lined up for CMS for revalidation, check out a copy of the Medicare enrollment form at www.cms.hhs.gov/MedicareProviderSupEnroll/02_EnrollmentApplications.asp. You'll notice that the agency requires a slew of information ranging from your organization name to your licensure status.

You may find pieces of this required information out of date. If that's the case, it's time to fix that fast and submit a fresh 855 form to CMS.

Important: As you update your information, consider consistency a top priority. "One of the biggest problem areas we find is that providers aren't consistent with names, among other things in their legal documentation," Brick says. For example, a home health agency may have opened with the name Pine Mountain Home Health Agency, bill under Pine Mountain Home Care and its information on file with CMS is Pine Mountain Home Health and Hospice. CMS won't go for that.

Critical: And now, with National Provider Identifiers going into full swing, the company name and other information you've filed on your NPI application must match your legal documentation. "Even if one little thing gets out of whack and CMS catches it, its contractors can stop reimbursement," Brick warns, "even something as small as your IRS information not matching your NPI information."

Helpful: See the article on the following page for a list of questions you should be asking when you audit your information on file.

Keep An Eye On The Timing

CMS is enforcing the revalidation process over a five-year period that went into effect last year, and the initial revalidation effort focused on Medicare contractors' top 100 billers.

But that doesn't mean you should wait for your carrier or FI to contact you. "CMS will continue to push forward with their revalidation efforts with smaller health care organizations as the effort phases in," Brick says. And you're much better off being prepared with your most up-to-date information on hand than to be scrambling to get your ducks in a row and risk having your billing privileges revoked.

Medicare providers have a lot of housecleaning to do in their legal documentation so they can turn in a clean and up-to-date 855 form. And from here on out, any time you have even the slightest change in your legal information--even if it's something as small as an address change--you need to notify Medicare of that change within 90 days.

Note: The MLN Matters article about the new forms, including a checklist of changes, is at www.cms.hhs.gov/MLNMattersArticles/downloads/SE0810.pdf.