Home Health & Hospice Week

Keep Your Enrollment Info Updated Or Lose Billing Privileges

Home health agencies that furnish flu vaccinations could be just one set of providers that sees their Medicare billing privileges revoked under new enrollment rules.

The Centers for Medicare & Medicaid Services proposes "to deactivate a provider or supplier's Medicare billing number if no Medicare claims are submitted for 2 consecutive calendar quarters (6 months)," according to the proposed rule in the April 25 Federal Register. That could mean all of a sudden, none of your claims will go through - and it could take weeks or months to sort out the problem.

Most HHAs that bill Medicare do so at least once every six months and usually much more often, notes consultant M. Aaron Little with BKD in Springfield, MO. But some providers furnish Medicare services very infrequently, such as flu shots that are provided during one season per year, notes consultant Tom Boyd with Rohnert Park, CA-based Boyd & Nicholas.

"We saw a greater number of LMU [low Medicare utilization] and NO Medicare business cost report filings than usual last month," when the majority of HHAs filed reports, Boyd tells Eli. "There are a number of entities who are Medicare certified but do not want to do much, if any, Medicare business."

And Boyd knows of at least two cases where those agencies are the only providers in the area to offer Medicare-reimbursed flu shots.

Billing Lapse Requires Recertification

If the proposed rule becomes final, those providers will see their billing rights rescinded, Boyd worries. And they will have to go through a significant paperwork hassle to get them back every time they lapse.

To reactivate their billing numbers, CMS says providers would have to re-certify that their enrollment information currently on file with Medicare is correct. And they'd have to meet all current Medicare requirements in place at the time of the reactivation.

HHAs with little Medicare business should reevaluate whether there is a great enough benefit to furnishing such a low amount of Medicare services to stay in the program, Little advises.

While deactivation for failure to bill may be infrequent, another proposed reason for deactivation could affect many more providers - and be harder to remedy.

CMS proposes that all providers must update the information on the enrollment form, CMS 855, "in a timely manner" if it changes. HHAs, durable medical equipment suppliers and other providers that fail to report a change of ownership or control within 30 days, or other changes to information on the form within 90 days, will see their ability to bill Medicare disappear overnight if the rule becomes final. Other information includes changes to billing services, location or managing employees.

This temporary deactivation wouldn't affect a provider's participation agreement or conditions of participation, CMS says. Rather, it would effectively be a financial penalty for failing to update information.

Failure To Update Requires New Form

Providers would have to complete and submit a new CMS 855 form to reactivate their numbers. CMS would give reactivations "priority handling to ensure expedient payment of claims," the proposed rule says. But whether that means restoration of billing in days, weeks or months is unclear.

At least reactivating billing rights wouldn't require a new survey or certification from the state, CMS says.

"This proposed penalty could certainly cause some problems for agencies that are unaware of the regulations," worries Little. Currently, providers are required to update the information but there is no penalty for failing to do so.

"Regulatory compliance is an important part of being successful in the home health environment," Little maintains. Proactive agencies should review their 855 information to make sure it is current. "This should prevent any unwanted surprises should the proposed rules become final," he says.

Editor's Note: The comment period for the proposal ended June 24. The rule is at http://cms.gov/providerupdate/regs/cms6002p1.pdf.