Home Health & Hospice Week

Regulations:

New Revalidation Requirements May Threaten Your Cash Flow

Look up your application due date on CMS website.

Don’t miss your Medicare revalidation deadline, unless you want to enroll from scratch and miss out on reimbursement in the meantime.

Medicare’s second cycle of provider revalidation began March 1, the Centers for Medicare & Medicaid Services notes on its website. CMS has listed all currently enrolled providers on its revalidation scheduling website, and your revalidation application is due on the last day of the month listed for you.

High stakes: CMS may put a hold on your Medicare payments and deactivate your Medicare billing privileges if you don’t submit your application on time, the agency stresses. “Deactivated providers will be required to submit a complete application to reactivate their enrollment,” CMS instructs.

If you fail to revalidate by the due date, you will have an additional 60 to 75 days to submit your revalidation application before becoming deactivated, explains the National Association for Home Care & Hospice in its member newsletter. Gap: Your reactivation date will be the date of receipt of your new complete application, CMS says on its revalidation site. “No payments will be made for the period of deactivation,” it stresses.

In other words, “CMS will not allow retroactive billing privileges back to the period of deactivation,” advises law firm Hall Render in analysis of the new procedure. “The provider or supplier will not be paid for any services provided during a period of deactivation.”

Difference: “A critical aspect … in cycle 2 is that once a provider/supplier has been deactivated there will no longer be a 120-day grace period before there is a gap in coverage,” NAHC emphasizes.

“A gap in coverage will occur from the date of deactivation until receipt date of the new full and complete application. In addition, provider/suppliers will not be issued a new PTAN when deactivated.”

Keep Track Yourself

Medicare Administrative Contractors are supposed to contact you a few months before your application is due, CMS notes. You’ll receive an email with “‘URGENT: Medicare Provider Enrollment Revalidation Request’ in the subject line to differentiate from other emails,” NAHC advises.

Do this: “Providers/suppliers are responsible to revalidate by their due date even if they do not receive any correspondence from their MAC,” NAHC warns. “Therefore, providers/suppliers are encouraged to keep track of their revalidation date and use the CMS revalidation list and tools.”

Time it right: Don’t jump the gun on applying for revalidation, however. CMS requests providers with a due date more than six months away, or those with a “TBD” due date designated to hold off on submitting an application. “Any revalidations received by CMS from providers or suppliers that have a TBD due date, or if their due date is greater than six months away, will be returned to the provider or supplier as an unsolicited revalidation submission,” Hall Render notes.

Exception: Durable medical equipment suppliers won’t have a due date on the website. “Instead, DMEPOS suppliers will receive communication from the National Supplier Clearinghouse (NSC) identifying when their revalidations are due,” CMS explains.

Keep Tabs On Docs

For home care providers, you must also keep track of your referring physicians’ enrolment status, NAHC reminds providers. “It is important to confirm that the ordering physician have an active enrollment record prior to accepting the referral,” the trade group urges. “Home health claims will be denied if the physician listed on the claim has been deactivated as of the ‘from’ date on claim.” And since there is no longer a grace period before a gap in coverage occurs, “retroactive billing privileges back to the period of deactivation will not be granted,” NAHC stresses.

Note: More details including links to the revalidation schedule (updated bimonthly) and FAQs are at www.cms.gov/medicare/providerenrollment-and-certification/medicareprovidersupenroll/revalidations.html.

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