Home Health & Hospice Week

Enrollment fraud demo to start Oct. 31.

You'll do well to count the reasons the feds' Form 855 has new meaning for you--or you could wind up with a slew of unpaid Medicare claims and little recourse.

Background: Back in April 2006, the Centers for Medicare & Medicaid Services published a final rule in the Federal Register spelling out new requirements for Medicare enrollment and reenrollment--processes that require the submission of Form 855. The rule requires that all providers and suppliers periodically update and certify the accuracy of their enrollment information. If they fail to, they forfeit their Medicare billing privileges.

But that's not all: CMS has put the spotlight even more squarely on the reenrollment process this year through several fraud demonstration programs affecting both Medicare-certified home health agencies and suppliers of durable medical equipment, prosthetics, orthotics and supplies (DMEPOS) (see Eli's HCW Vol. XVI, Nos. 24, 26 and 31).

Does Demo's Halloween Start Date Scare You?

The agency announced in mid-October that a large demonstration affecting hundreds of HHAs in Texas and California would kick off by Oct. 31.

For agencies and suppliers affected by the demonstration, the price for failing to complete the reenrollment process properly is the same as for others asked to reenroll: the loss of Medicare billing privileges.

"They can't take away your certification without due process, but losing your billing privileges essentially has the same affect," notes Bobby Dusek, a consultant based in Abilene, TX.

Look for: If you are in Harris County, TX or the counties of Los Angeles, Orange, Riverside, or San Bernardino in California, you'll be receiving a "revalidation request" some time soon from your intermediary, says CMS. About 840 "demonstration agencies" will be affected.

Outside of the demonstration areas, any provider that hasn't reenrolled in the last five years could be called on to file Form 855A (for HHAs) or Form 855S (for DMEPOS suppliers).

Be Careful Or Pay The Price

Though the demonstration is intended to ferret out fraudulent players, unsuspecting reputable providers could be penalized if they don't take precautions in completing the reenrollment process, warns Elizabeth Hogue, an attorney in Burtonsville, MD.

Be diligent in filling out the form accurately and completely, ideally seeking counsel from an attorney or knowledgeable consultant.

Big risk: "Providers and suppliers need to understand that CMS has instructed the intermediaries that there are no second chances to complete the form accurately," she says. "If you submit it with errors, you can no longer bill Medicare."

Don't delay the process once you receive a revalidation request.

"You have not months, but days" to comply, stresses Hogue.

Demonstration HHAs have just 60 days from the date of the letter to submit a complete 855A provider enrollment application with all supporting documentation to the contractor that sent the letter. DMEPOS suppliers in the demonstration have to act even more quickly, submitting Form 855S within 30 days.