Practice Management Alert

When's the last time you revalidated your providers- CMS-855 form? If you haven't done it within the past five years or if your provider's information changed, you-d better get busy. Now is the time to ensure you understand Medicare's revalidation process -- because if you-re slacking, your Medicare carrier can retract your billing privileges.

Background: In the April 21, 2006, Federal Register, CMS instructed all Medicare providers to 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.

While that sounds simple enough, many providers have never filed a complete CMS-855, which can make the revalidation process quite difficult, Brick says. And you may even receive an on-site survey if CMS discovers enough discrepancies.

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

If you-re not sure what kind of information you need to have 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You may find that pieces of this required information are out of date for your practice or facility, so it's time to fix that fast and submit a fresh 855 form to CMS.

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 opened with the name Spring Valley Medical Center, but it bills as Spring Valley Family Practice, and its information on file with CMS may say Spring Valley Family Medi-cine. And CMS won't go for that.

Critical: 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 docu-mentation. "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."

Note: "When the NPPES [National Plan and Provider Enumeration System] information doesn't match what the physicians have used, the rush is on to get things changed," says Leslie Johnson, CCS-P, CPC, manager/ consultant of coding and compliance for DR Management in Fort Wayne, Ind. "The changes can take months -- new forms need to be filled out, and meanwhile, payments will stop because everything is inconsistent."

Bonus: See the article on the next page for a list of questions you should be asking when you audit your in-formation on file.

The CMS revalidation process is being enforced over a five-year period that went into effect last year, and the initial revalidation effort focused on Medicare contractors- top 100 billers. But that doesn't mean you should wait for your carrier to contact you.

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

Bottom line: 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 even the slightest change in your legal information, even if it's something as small as an address change, you need to notify Medicare of that change within 90 days.

Resources: See the rule's text at http://edocket.access.gpo.gov/cfr_2006/octqtr/pdf/42cfr424.515.pdf.