I recently had the pleasure of attending the 2019 CMS National Provider Enrollment Conference on March 12 and 13th in Nashville, Tennessee. As always, the conference was an absolute delight and full of great information, minds, and ideas. The conference also does a great job of outlining important CMS policy changes. For a breakdown of all the changes you need to be aware of, continue reading below.
New and Revised Revocation Authorities
- Failure to report: Currently applies only to physicians and practitioners, but if finalized it will apply to all types of providers and suppliers.
- Other program termination: CMS can revoke Medicare from programs that have been terminated, revoked, or barred from state Medicaid programs, as well as any other healthcare program.
- Debt referred to the United States Department of Treasury: CMS will refer debt to the United States Department of Treasury.
- “Revoked under different “identity”: CMS can now revoke Medicare if they find that a provider has been revoked already under a different name, numerical identifier, or business identity.
- Negative affiliations: CMS may revoke Medicare if determined that the provider has risky affiliations that may lead to fraud, waste, or abuse of the program.
- Billing from non-compliant location: CMS can revoke enrollment and all practice locations if billing occurs at a location that does not comply with Medicare enrollment requirements.
- Abusive ordering, certifying, referring, or prescribing Part A or B services, items or drugs: If a physician or professional is found to have a pattern of ordering, referring, prescribing, or certifying Medicare Part A or B services, drugs, or items in an abusive manner that threatens the safety and health of Medicare beneficiaries, CMS may revoke.
New/Revised Denial Authorities
- Payment suspensions: CMS may deny enrollment based on Medicare or Medicaid suspension.
- Other program termination or suspension: CMS can deny participation if a provider’s license has been revoked or suspended in another state
- Denial based on different name and negative affiliations: See Revocation above
- 3-year penalty for trying to circumvent reenrollment bar: CMS may extend a provider or supplier’s reenrollment bar if it finds that they have been trying to get around their current bar.
- Extension of revocation: CMS is able to revoke any and all of a provider/supplier’s Medicare enrollments, as well as those who identify under different names
- Opt-out change: If the revision is finalized, providers who are revoked will not be able to order, certify, or prescribe for medicare beneficiaries.
As always, the provisions to CMS policies are extensive. The session that explained the provisions was well done, offering numerous examples and answering any questions that were bound to arise. Stay tuned for more information on the CMS Provider Enrollment Conference.