Medicare Compliance & Reimbursement

• You may have a few more hassles to deal with as CMS tightens up its enrollment procedures. When a contractor denies an enrollment application or revokes billing privileges based on "adverse legal action," it now will search PECOS to see whether the provider or its principal owners and management have any other Medicare entity associations, CMS says in Dec. 19 CR 6097. If so, the contractor will initiate revocation procedures for the other providers, too.

Contractors will also be pickier about home health agencies that share the same address. CMS strongly encourages site visits for HHAs listed with the same address as another agency that is already enrolled or in the process of enrolling in Medicare, the CR says.

Another thing: Until a change of ownership (CHOW) is complete and the "tie-in notice" issued, contractors should also ignore any requests from the seller to change the payment address, physical address, and/or ownership to that of the new buyers, CMS instructs in the transmittal. Ditto for any requests at all from the buyers.

The transmittal is online at www.cms.hhs.gov/transmittals/downloads/R277PI.pdf.

On the other hand: In another transmittal regarding enrollment appeals, CMS may make such appeals easier by instructing contractors to explain the reason for a denial "in sufficient detail to allow the provider or supplier to understand the nature of its deficiencies," according to Dec. 12 CR 6248 (Transmittal No. 275).