Practice Management Alert

Do you scrutinize your physician enrollment forms before you send them off to Medicare? If not, your practice might get a visit from the feds. That's right, your practice could be subjected to site visits from federal regulators who want to verify the enrollment information you've provided on the CMS 855 form if an April 25 proposal from CMS becomes final. When CMS proposes a rule, it usually allows a comment period during which providers and other interested parties can weigh in with their thoughts on how the rule will effect them. In this case, you get until June 24 to comment. CMS will then consider the comments and publish the final version later this summer. The 200-plus page rule is designed to establish a process that ensures qualified providers can participate in the program while bad apples are weeded out. The possibility that an incorrectly completed 855 form could trigger site visits from federal regulators worries some experts. It's not clear from the proposed regulation exactly what the "visitors" would be looking for, notes Robert Polglase, MD, JD, CEO of Strategem Group, Inc. in Augusta, Ga. All of CMS's plans for 855 have the potential to throw a wrench in a provider enrollment process that's already often cumbersome and time-consuming for medical practices and billing companies, Polglase worries. CMS seems to recognize this problem as well, and notes that it's considering "a variety of ways" to make the process less painful for physicians'offices and other providers. If CMS'proposed enrollment reg flies largely as written  and the chances of that are good  physicians' offices will face a more convoluted Medicare enrollment process than ever before.

Here's a Sampling of What's to Come   Cross yourT's and dot your I's on the 855. When submitting the CMS 855, the proposal says providers must be sure to include "complete and accurate responses to all information requested" in the sections that apply to your situation.

Also be sure to submit any documentation CMS currently requires as identification, as well as any documentation currently required to establish a physician's eligibility to furnish services to Medicare beneficiaries.      Revisit your information every third year. Under the rule, providers will have to re-verify their enrollment information every three years. And if there are any changes to your information, you must report them within 90 days or risk having your Medicare billing privileged revoked, the rule proposes.

Also, if your information hasn't changed and CMS hasn't heard anything out of you for three years, the agency proposes to contact physicians'offices to revali-date doctors'billing privileges. As part of this "routine revalidation," your office may or may not receive a visit from a Medicare rep  CMS reserves the right to conduct [...]