Medicare Revalidation Alert

CMS ANNOUNCES THAT REVALIDATION WILL COMMENCE FOR ALL PROVIDERS

All providers and suppliers who enrolled in the Medicare program prior to March 25, 2011, will be required to revalidate their enrollment under new risk screening criteria required by the Affordable Care Act (section 6401a). Newly-enrolling and revalidating providers and suppliers are placed in one of three screening categories representing the level of risk to the Medicare program. The three categories, limited, moderate, or high, determine the degree of screening to be performed by the Medicare Administrative Contractor (“MAC”) processing the enrollment application.

The Centers for Medicare and Medicaid Services (CMS) announced that all providers will be subject to revalidation once they receive a written request to do so. CMS will begin notifying physicians and entities to revalidate in September. Their plan is to start with those physicians and other organizations who are enrolled in Medicare, but do not yet have complete profiles in PECOS (Provider Enrollment, Chain, and Ownership System). They will also send revalidation letters to all Independent Diagnostic Testing Facilities (IDTF). The remainder of the physicians and providers will receive letters over the next 19 months, in an order still to be determined. Upon receipt of the revalidation letter, physicians and organizations will have 60 days to respond.

Medicare providers will be required to submit a completed CMS Form 855A, or alternate, with supporting documentation within 60 days of the request. In addition, a $505 filing fee is required to be submitted if filed in 2011 (the fee increases in 2012).

After the CMS Form 855, and attachments, is filed, the MAC will review the form and initiate screening requirements. For many providers the screening requirements include a site visit. These visits are not for survey and certification purposes, but rather to ensure the provider is operational. Failure to submit a complete CMS Form 855 and the required documentation within 60 days of the request will result in deactivation of your Medicare enrollment.

ADVOCATE will continue to provide updates as they become available.

With best regards,
Kirk Reinitz, CPA
President & CEO