Medicare Compliance & Reimbursement

That time of year has come again -- time for CMS to issue yet another enrollment form, taking the enrollment and revalidation process into murky waters.

Last week, CMS revised CMS-855, the Medicare enrollment application, urging providers to begin using the new form "immediately," although the new form won't actually be required for physician practices to use until June.

The plus side: CMS has removed the previously existing directive on the CMS-855 that once required you to attach your NPI notification letter to the enrollment form. Starting with the new form, that additional form will no longer be required.

Keep in mind that the CMS-855 form isn't just for new enrollees -- you'll also need to use the form when it's time to revalidate your Medicare status.

Refresher: As most practices know, all Medicare providers must revalidate all of their Medicare information on file, via a CMS-855 form, within 60 days of receiving a written revalidation request from their CMS fiscal intermediary or carrier, says Lyndean Brick, JD, senior vice president of Murer Consultants Inc. in Joliet, IL.

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.

Important: As you update your information, consider consistency a top priority. Why? "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 practice may have first opened with the name Mountain Medicine, but it bills as Mountain Sports Medicine, yet its information on file with CMS may say Mountain Orthopaedics. And CMS won't go for that.

Critical: And now, with NPIs going into full-swing, the practice or facility 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."

You can download the new CMS-855 forms from http://www.cms.hhs.gov/CMSForms.