June 27, 2016
Every physician, nurse anesthetist or anesthesiologist assistant who bills Medicare should make sure to revalidate their enrollment information by their individual due date. Medicare recently began the second cycle of revalidations. Practices should be alert to the notices they will receive from their MACs.
All physicians, group practices and other providers who participate in Medicare are required to resubmit and recertify the accuracy of their enrollment information every five years through a revalidation process.
Section 6401 (a) of the Affordable Care Act established new screening requirements for providers; required them to be revalidated under those new requirements, and reinforced the revalidation regulations at 42 CFR §424.515. The first cycle of enrollment revalidations ended as the second cycle began in March 2016.
Required Actions
Physicians and other clinicians must submit their revalidation applications by the last day of the month in which they are due. Your Medicare Administrative Contractor (MAC) is expected to notify you of the due date within two to three months of your revalidation deadline, by email or by regular mail. Generally, this due date will remain with you throughout subsequent revalidation cycles.
Centers for Medicare & Medicaid Services (CMS) also maintains a list of individual providers and their due dates at www.data.CMS.gov/revalidation. A “TBD” (to be determined) notation means that your due date is more than six months away. Due dates are updated every 60 days at the beginning of the month. The revalidation lookup tool has a crosswalk linking it information on the employers to whom the clinician has reassigned his or her benefits. Anesthesia professionals should check the list periodically to determine whether their due date is approaching.
The MACs will continue to issue revalidation notices in addition to the posted list. If you are within two months of your listed due date but have not received a notice from your MAC to revalidate, CMS nevertheless encourages you to submit your revalidation application using the Internet-based Provider Enrollment, Chain and Ownership System (PECOS) at www.PECOS.cms.hhs.gov or the appropriate CMS-855 form. PECOS is, of course, the fastest option. If you have a fee due, use PECOS to pay. Once a physician submits their application online they are required to immediately print, sign, date, and mail the certification statement along with all required supporting documentation to their contractor.
If a revalidation application is incomplete, your MAC may request additional information. Practices should respond to all MAC requests within 30 days.
Contents of the Revalidation Application
Revalidate your entire enrollment record either via PECOS (most efficient) or on paper. Include all active practice locations and current reassignments of benefits, and see the Revalidation checklist. Note in particular that non physician practitioners (NPPs) such as CRNAs must provide a copy of board certifications.
Anesthesia professionals who reassign their benefits to several groups must ensure that all of their enrollment information for each group is included in a single revalidation application. Individual physicians and NPPs are responsible for ensuring that when they submit their revalidation application, all solo practice locations (if applicable) and groups to whom they reassigned benefits are accounted for. If a practice location or group reassignment name is missing from the revalidation application, practice locations and missing group reassignments could result in deactivation of the associated Provider Transaction Access Numbers (PTANs).
In its Revalidation FAQs, CMS answered a question regarding whether “large groups continue to be contacted separately for revalidation” stating:
All providers, including large groups will receive a request to revalidate. Separately, the MAC will also send each practitioner a request to revalidate. If the group is completing the revalidation on behalf of the practitioner and the practitioner reassigns to multiple groups, CMS encourages the groups to work with their practicing practitioners to ensure that the practitioner’s revalidation application is complete and addresses all active practice locations and reassignments and that it is submitted by the due date.
The MACs will continue to contact large groups (200+ members). Large groups will receive letters from their MACs detailing their reassigned practitioners who are required to revalidate in the next six months. A spreadsheet detailing the applicable practitioner’s Name, National Provider Identifier (NPI) and Specialty will be provided. We encourage all groups to work together as only one application from each provider/supplier is required, but the practitioner must list all groups they are reassigning to on the revalidation application submitted for processing. MACs will have dedicated provider enrollment staff to assist in the large group revalidations.
Consequences of Being Too Early/Too Late
Unsolicited revalidation applications submitted by practices or clinicians who are not due to revalidate will be returned. (Physicians and nurses are not due to revalidate if they display a TBD on the Revalidation Lookup Tool, and a revalidation notice has not been received from their MAC requesting them to revalidate, or if the application is submitted more than six months in advance of the due date).
If the physician’s application is received after the due date, or if he or she provides additional requested information after the due date (including an allotted time period for U.S. or other mail receipt), that physician’s enrollment record will be deactivated. Deactivated providers will be required to submit a full and complete application in order to reestablish their provider enrollment record and related Medicare billing privileges. The provider/supplier will maintain their original PTAN; however, an interruption in billing will occur during the period of deactivation resulting in a gap in coverage. There will be no retrospective payment for any services performed during the period of deactivation, so it is very important to maintain your enrollment status.
The Medicare provider enrollment revalidation effort does not change other aspects of the enrollment process. Providers should continue to submit changes (for example, changes of ownership, change in practice location or reassignments, final adverse action, changes in authorized or delegated officials or, any other changes) as they always have. If you intend to submit a change to your provider enrollment record, submit a ‘change of information’ application using PECOS or the relevant form CMS-855.
We hope that this information is helpful.
With best wishes for the Fourth of July holiday,
Tony Mira
President and CEO
