Medicare Physician Revalidation Extended Two Years to March 2015 and a Sample Revalidation Letter
IMPORTANT: This does not affect those providers which have already received a revalidation notice. If you have received a revalidation notice from your contractor, respond to the request by completing the application either through internet-based PECOS or completing the appropriate 855 application form.
The first set of revalidation notices went to providers who are billing, but are not currently in the Provider Enrollment, Chain and Ownership System (PECOS). To identify these providers, contractors searched their local systems and if a Provider Transaction Access Number (PTAN) for a physician was not in PECOS, a revalidation request for that physician was sent. CMS asks all providers who receive a request for revalidation to respond to that request.
For providers NOT in PECOS – the revalidation letter will be sent to the special payments or primary practice address because CMS doesn’t have a correspondence address. For providers in PECOS – the revalidation letter will be sent to the special payments and correspondence addresses simultaneously; if these are the same it will also be mailed to the primary practice address. If you believe you are not in PECOS and have not yet received a revalidation letter, contact your Medicare contractor. Contact information may be found here.
Institutional providers (i.e., all providers except physicians, non-physician practitioners, physician group practices and non-physician practitioner group practices) must submit the application fee with their revalidation. In mid-September, CMS revised the revalidation letter that contractors sent to providers to clarify who must pay the fee.
CMS plans to post a list of providers who were sent requests to revalidate. They will make an announcement via CMS listservs when this information is posted.
See sample revalidation letter below.
THIS IS A REVALIDATION REQUEST IMMEDIATELY SUBMIT AN UPDATED PROVIDER ENROLLMENT PAPER APPLICATION 855 FORM OR REVIEW, UPDATE AND CERTIFY YOUR INFORMATION VIA THE INTERNET-BASED PECOS SYSTEM
CITY STATE ZIP CODE
Dear Provider/Supplier Name:
In accordance with the Patient Protection and Affordable Care Act, Section 6401 (a), all new and existing providers must be reevaluated under the new screening guidelines in Section 6028. Medicare requires all enrolled providers & suppliers to revalidate enrollment information every five years (reference 42 CFR § 424.57(e)). To ensure compliance with these requirements, existing regulations at 42 CFR § 424.515(d) provide that CMS is permitted to conduct off-cycle revalidations for certain program integrity purposes. Upon the CMS request to revalidate its enrollment, the provider/supplier has 60 days from the date of this letter to submit complete enrollment information using one of the following methods:
Providers and suppliers can enroll in the Medicare program using either the:
(1) Internet-based Provider Enrollment, Chain, and Ownership System (PECOS).
To revalidate via the Internet-based PECOS, go to https://pecos.cms.hhs.gov. This system allows you to review information currently on file, update and submit your revalidation via the internet. Once submitted, be sure to print, sign, date, and mail the certification statement along with all required supporting documentation. In order for us to process the revalidation, the original signature and documentation must be received within 15 days of internet submission.
Physicians and non-physician practitioners will access Internet-based PECOS with the same User ID and password that they use for NPPES. For assistance in establishing an NPPES User ID and password, or if you have forgotten your ID or password or wish to change your NPPES password, contact the NPI Enumerator at 1-800-465-3203 or TTY 1- 800-692-2326, or send an e-mail to email@example.com
For provider/supplier organizations, your Authorized Official must register with the PECOS Identification and Authentication system. If you have not registered, do so now by going to (https://pecos.cms.hhs.gov). This registration process can take up to three (3)weeks. If additional time is required to complete the revalidation, you may request one 60-day extension, which will begin on the date of the request.
To avoid any registration issues, review the internet-based PECOS related documents available on the CMS Web site (www.cms.hhs.gov/MedicareProviderSupEnroll).
(2) Paper Application Process
To revalidate by paper, download the appropriate and current CMS-855 Medicare Enrollment application from the CMS Web site at www.cms.hhs.gov/cmsforms. Mail your completed application and all required supporting documentation to the [insert contractor name], at the address below.
[Insert application return address]
With the exception of physicians, non-physicians practitioners, physician group practices and non-group practices, providers and suppliers that are revalidating their enrollment information must submit with their application an application fee.
The 2011 application fee of $505 or a request for hardship exception must be included with the provider enrollment application. Submit the enrollment fee via Pay.Gov prior to submitting the application (reference 42 CFR 424.514). You can submit your application fee by electronic check, debit or credit card. If you feel you qualify for a hardship exception waiver, submit a letter and financial statements to request a waiver in lieu of the enrollment fee along with your application or certification statement. Revalidations are processed only when fees have cleared or the hardship waiver has been granted. You will be notified by mail if your waiver request has been granted or if a fee is required.
For more information on the application fees and other screening requirements under the PPACA view the MLN Matters Article at http://www.cms.gov/MLNMattersArticles/downloads/MM7350.pdf.
You are required by regulations found at 42 CFR 424.516 to submit updates and changes to your enrollment information in accordance with specified timeframes. Reportable changes include, but are not limited to changes in: (1) legal business name (LBN)/tax identification number (TIN), (2) practice location, (3) ownership, (4) authorized/delegated officials, (5) changes in payment information such as changes in electronic funds transfer information and (6) final adverse legal actions, including felony convictions, license suspensions or revocations of a health care license, an exclusion or debarment from participation in Federal or State health care program, or a Medicare revocation by a different Medicare contractor.
Failure to submit complete enrollment application(s) and all supporting documentation within 60 calendar days of the postmark date of this letter may result in your Medicare billing privileges being deactivated.
If you have any questions regarding this letter, please call [contractor telephone number will be inserted here] between the hours of [contractor telephone hours will be inserted here] or visit our Web site at [insert Web site] for additional information regarding the enrollment process or the [insert application type].
I am retired and can find no info in any of your communications about whether there is anything I need to do. I assume I need to do nothing and my MC billing privileges will just cease. Please advise.
You will need to inactivate your NPI record, which will let Medicare know you are no longer practicing. I just checked your NPI record and you are still listed as active. The NPI registry states the following:
Special Note to Physicians and Other Practitioners Concerning National Provider Identifiers (NPIs):
If you voluntarily surrender your license or retire and you will no longer be furnishing health care in this
or any other State, please remember to deactivate your NPI in NPPES
(https://nppes.cms.hhs.gov/NPPES/Welcome.do). Deactivating your NPI will help ensure that your NPI
is not used fraudulently by others. If you do not know how to deactivate your NPI, you may contact the
NPI Enumerator at 1-800-465-3203 for assistance.
Good Luck and Happy Retirement!
I am a provider and need to check my status of an active provider. How do I do this. I am working as an independent contractor for a company, and they are billing under his NPI. Is this legal? Shouldnt I be creditialed at this company?
You can check your status as an active provider here: https://npiregistry.cms.hhs.gov/NPPESRegistry/NPIRegistryHome.do
Each state defines how NPs can practice and each payer (Medicare, BCBS, Aetna, etc.) defines how services by an NP can be billed. Typically, billing software has a field for entering the rendering provider’s name/NPI and the supervising or attending physician’s name/NPI. When the NP is credentialed to with a payer, her name goes in both fields. When the NP is not credentialed with a payer, her name goes in the rendering field and the physician’s name goes in the supervising/attending field.
Many payers also define what “supervision by a physician” means as far as does the physician have to be available by phone, or in the clinic and does the physician have to countersign the medical record or not. Medicare is the most straightforward of the payers – NPs are not able to see new Medicare patients or established patients with new problems by themselves as Medicare wants the physician to create the assessment and treatment plan. For established patients with existing problems, the NP can see the patient herself and Medicare will pay 85% of the allowable. Other payers are not nearly so clear.
To the best of my knowledge (as Clinic Manager and Credentialing officer for our group of three providers), I have never seen any written requests from CMS nor our State Medicare Contractor, requesting our PECOS revalidation. I have been closely watching the mail for over 6 months and still havent seen it. Where can I go/Who can I ask to confirm that indeed it hasn’t been mailed and that it isn’t required at this time? As Clinic Manager I can not possibly rely on receiving or not receiving mail as a our indication of such an important event. Please advise.
Hi Mary Jo,
Here is the link to review who CMS has mailed about revalidations: http://go.cms.gov/Z0YcIt