Neurosurgery Coding Alert

If your practice bills Medicare, you need to get a handle on Medicare's revalidation process immediately. Failing to do so allows your carrier or fiscal intermediary to pull the plug on your billing privileges.

Background: According to CMS ruling 42 CFR 424.515 in the April 21, 2006, Federal Register, all Medicare providers must revalidate 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, Ill.

There's more: "Generally speaking, after a provider submits a complete CMS-855, either in response to a revalidation request or otherwise, the provider must then revalidate his or her entire CMS-855 filing once every five years -- or within 90 days after any change in his or her Medicare provider information," Brick says.

If you-re not sure what kind of information you need to have lined up for CMS for revalidation, check out a copy of the Medicare enrollment form at http://www.cms.hhs.gov/cmsforms/downloads/cms855i.pdf.

You-ll notice that the agency requires a slew of information ranging from your practice name to your licensure status. You may find that pieces of this required information are out of date for your practice or facility, and if that's the case, you should fix that fast and submit a fresh 855 form to CMS.

Important: As you update your information, consider consistency a top priority. "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.

Critical: And now, with national provider identifier (NPI) requirements in 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 says, "even something as small as your IRS information not matching your NPI information."

Tip: See below for a list of questions you should be asking when you audit your information on file.

CMS will enforce the revalidation process over a five-year period that began last year. The initial revalidation efforts have focused on Medicare contractors- top-100 billers -- but that doesn't mean you can't ready your practice now.

"CMS will continue to push forward with its revalidation efforts with smaller healthcare organizations as the effort phases in," Brick says. You-re much better off being prepared with your most up-to-date information on-hand than to be scrambling and risk having your billing privileges revoked.

In short: Medicare providers have a lot of housecleaning to do in their legal documentation so they can turn in a clean and up-to-date 855 form. And from here on out, anytime you have a change in your legal information, even something as small as an address change, you need to notify Medicare of that change within 90 days.

Resources: To view the entire rule, go online to http://a257.g.akamaitech.net/7/257/2422/13nov20061500/edocket.access.gpo.gov/cfr_2006/octqtr/pdf/42cfr424.515.pdf.