Home Health & Hospice Week

Do Not Forward initiative makes moving a payment nightmare. Medicare needs to work out its procedures for supplier location changes, or it will be suppliers who pay the price.

In previous forums, suppliers said they are afraid to move because it is so difficult to coordinate change of address procedures between the National Supplier Clearinghouse and the durable medical equipment regional carriers (DMERCs).

The problem is that if even one piece of mail from a DMERC is returned because the supplier has moved, the Do Not Forward initiative kicks in and all the supplier's subsequent mail -- including reimbursement checks -- are held up, explained attorney Seth Lundy with Fulbright & Jaworski in Washington DC.

The Centers for Medicare & Medicaid Services said the NSC can't make an address change -- and pass it onto the DMERCs -- until the move actually occurs. Plus, the NSC must be able to conduct a site visit at the new address and all licenses and insurance must reflect the new address, a CMS official said in the April 28 Open Door Forum for home health.

Suppliers should work with licensing agencies ahead of the move so they can secure a letter or oral assurance of the address change, if they can't get the license itself, the CMS staffer advised.

But that doesn't solve the DNF problem, which hangs up payments, Lundy lamented in the forum. If the NSC notifies the DMERC the day the supplier moves, there still will be items already in the mail that will trigger the Do Not Forward hold.

"There needs to be some way that the [NSC, DMERC and supplier] can communicate to prevent that Do Not Forward from happening when the NSC is notified sufficiently in advance of the move," Lundy said. He asked if DMERCs can just hold suppliers' mail until a change of address is completed.

Although skeptical, CMS promised to look into the matter. In the meantime, CMS said the NSC will give suppliers under a Do Not Forward status "priority attention."

DMERC Reg Explained

Meanwhile, the main aim of the regulation CMS issued on redefining DMERC boundaries is to balance workloads between the contractors, CMS said in the forum (see Eli's HCW, Vol. XIII, No. 13).