Medicare Compliance & Reimbursement

Even a new phone number can trigger an 855 submission

Be prepared for a challenge when it's your turn to reenroll in Medicare. The Centers for Medicare & Medicaid Services (CMS) revised its series of 855 forms last year, but that doesn't mean the process will be easy.

Experts offer these tips to steer clear of trouble:

• Be aware of all re-enrollment triggers. Every provider should be well versed in the requirements spelled out in the feds' final rule on establishing and maintaining enrollment in the Medicare program, instructs Bobby Dusek, a consultant in Abilene, TX.

Top triggers: You must take the initiative to update CMS using Form 855. For example, an update is required if your organization experiences a change in location or change in management personnel.

Little change, big implications: Even a new telephone number triggers the need to update CMS using Form 855. Failure to do so marks you as noncompliant, and you're at risk for losing your Medicare billing privileges, explains attorney Elizabeth Hogue, based in Burtonsville, MD.

Your intermediary may also initiate the process. This typically happens when five or more years have elapsed since the last submission of Form 855.

"You're due to re-enroll every five years, but the process starts only when you receive a revalidation request from the intermediary," notes Dusek.

• Be on time. If you receive a revalidation request, be sure you know how long you have to reply. Under the demonstration, CMS will revoke a home medical equipment supplier's Medicare billing privileges when the supplier fails to submit a Form 855 application within 30 days.

Suppliers of durable medical equipment, prosthetics, orthotics and supplies (DMEPOS) affected by the demonstration should also note this short deadline: Failure to report a change in ownership or address at least 30 days prior to the change's effective date can result in a loss of billing privileges.

• Be more than "just a number." Be sure to establish contact with a representative at the Medicare contractor handling your re-enrollment process, urges Hogue. Fail to, and you are nothing more than a number to CMS.

"Speak to the person regularly and document everything," she says. That dialogue will earn you extra rights in many cases. The final rule, for example, states that CMS may, at its discretion, "choose to extend the 60-day period if [the agency] determines that the provider or supplier is actively working with CMS" to resolve snags in the process.

• Don't delegate. CMS asks each provider or supplier going through enrollment and re-enrollment to name a primary contact.

"The highest level manager should be the contact," says Hogue. Naming a low-level clerical person is asking for something vital to be overlooked, she adds.

Resources: To see the final rule, "Medicare Program: Requirements for Providers [...]