The Centers for Medicare & Medicaid Services (CMS) has extended the revalidation period for another 2 years. This will allow for a smoother process for provider and contractors. Revalidation notices will now be sent through March of 2015.
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.
CMS will hold a National Provider Call to discuss the revalidation of Medicare provider enrollment information on Thursday, October 27th, 2011; from 12:30 – 2PM Eastern. Most providers and suppliers who are enrolled in the Medicare program will have to revalidate their enrollment which will be reviewed under the new risk screening criteria required by the Affordable Care Act Section 6401(a). Learn what you can expect and how to prepare for this process.
Target Audience: All providers and suppliers enrolled with Medicare prior to March 25, 2011 and who expect to receive payment from Medicare for services provided!!!!!! (I had to add those exclamation points – what a statement – if you expect to be paid, you need to revalidate.)
The agenda will include:
What is Revalidation?
ACA Screening Requirements
Electronic Funds Transfer
Streamlining the Process
Phased Revalidation
Tips on Revalidation
Question and Answer Session (my favorite!)
Registration Information: In order to receive the call-in information, you must register for the call. Registration will close at 12pm on Thursday, October 27, 2011 or when available space has been filled; no exceptions will be made, so please register early. For more details, including instructions on registering for the call, click here. The audio recording and written transcript will be posted after the call.
Presentation: The presentation will be posted at least one day before the call in the “Downloads” section of the page here.
For more information about provider enrollment revalidation, review the Medicare Learning Network’s® publication here.
All providers and suppliers who enrolled in the Medicare program prior to Friday, March 25, 2011, will be required to revalidate their enrollment under new risk screening criteria required by the Affordable Care Act (section 6401a). Providers/suppliers who enrolled on or after Friday, March 25, 2011 have already been subject to this screening, and need not revalidate at this time.
New Screening Criteria
In the continued effort to reduce fraud, waste, and abuse, CMS implemented new screening criteria to the Medicare provider/supplier enrollment process beginning in March 2011. Newly-enrolling and revalidating providers and suppliers are placed in one of three screening categories – limited, moderate, or high – each representing the level of risk to the Medicare program for the particular category of provider/supplier, and determining the degree of screening to be performed by the Medicare Administrative Contractor (MAC) processing the enrollment application. More information on the screening categories is here.
Notices Will Be Sent to Providers/Suppliers
Between now and March 2013, MACs will be sending notices to individual providers/suppliers; please begin the revalidation process as soon as you hear from your MAC. Upon receipt of the revalidation request, providers and suppliers have 60 days from the date of the letter to submit complete enrollment forms. Failure to submit the enrollment forms as requested may result in the deactivation of your Medicare billing privileges. The easiest and quickest way to revalidate your enrollment information is by using Internet-based PECOS (Provider Enrollment, Chain, and Ownership System), at https://pecos.CMS.hhs.gov.
Fees Levied
Section 6401a of the Affordable Care Act requires institutional providers and suppliers to pay an application fee when enrolling or revalidating (“institutional provider” includes any provider or supplier that submits a paper Medicare enrollment application using the CMS-855A; CMS-855B, not including physician and non-physician practitioner organizations; CMS-855S; or associated Internet-based PECOS enrollment applications); these fees may be paid via www.Pay.gov.
In order to reduce the burden on the provider, CMS is working to develop innovative technologies and streamlined enrollment processes – including Internet-based PECOS. Updates will continue to be shared with the provider community as these efforts progress.
For more information about provider revalidation, review the Medicare Learning Network’s Special Edition Article #SE1126, titled “Further Details on the Revalidation of Provider Enrollment Information.”
First the facts on what has taken place so far in the 2011 EHR Incentive Programs.
As of June 30th, the total of Medicare EHR Incentive Program payments is over $94 million.
As of June 30th, over $166 million has been paid in Medicaid EHR incentives since the program began in January. In May and June, four states launched Medicaid EHR Incentive Programs – Indiana, Ohio, Pennsylvania, and Washington, bringing the total states with Medicaid EHR Incentive Programs to 21. More states will launch in July.
There are 68,001 active registrations of eligible professionals and eligible hospitals for the Medicare and Medicaid EHR Incentive Programs.
If your group hasn’t received a check and hasn’t registered for the Medicare or Medicaid Incentive Program, then this blog post is for you! For anyone who is really just beginning their EHR journey, today’s presentation clarified previous information given by CMS, as well as giving listeners new information about the programs.
Note: see my latest post on registering and attesting for the EHR Incentive Program here.
Registration opens on January 3, 2011 for the Medicare and Medicaid EHR Incentive Programs
Register as soon as possible after January 3, 2011.
You can register before you have a certified EHR, but you will have to have an EHR when you attest.
You can register even if you do not have an enrollment record in PECOS.
A link to the Incentive Registration will be available here when it is published.
Not all states will be ready to participate in the Medicaid program on January 3rd. Information by state is here.
What do you have to have to register?
A National Provider Identifier (NPI) All eligible professionals, eligible hospitals, and critical access hospitals (CAHs) must have a National Provider Identifier (NPI) to participate in the Medicare and Medicaid EHR Incentive Programs.
An enrollment record in the Provider Enrollment, Chain and Ownership System (PECOS) All eligible hospitals and Medicare eligible professionals must have an enrollment record in PECOS to participate in the EHR Incentive Programs. Eligible professionals who are only participating in the Medicaid EHR Incentive Program are not required to be enrolled in PECOS. If you do not have an enrollment record in PECOS, you should still register for the Medicare and Medicaid EHR Incentive Programs.
CMS Identity and Access Management (I&A) User ID and Password
Eligible Professionals: Eligible professionals can use the same User ID and Password they use for the National Plan and Provider Enumeration System (NPPES). This is also the same User ID and Password that is used to access PECOS. If you do not have an active User ID and Password for NPPES or PECOS, request them here. You will need your type 2 NPI, your Taxpayer Identification Number (TIN), and your address from IRS Form CP-575. You will also need to mail a copy of IRS Form CP-575 as directed.
Hospitals/Critical Access Hospitals: Authorized Officials can use the same User ID and Password they use to access PECOS. If you do not have an Authorized Official with access to PECOS, request a User ID and Password here. You will need your type 2 NPI, your Taxpayer Identification Number (TIN), and your address from the IRS Form CP-575. You will need to mail a copy of the IRS Form CP-575 as directed. Additional hospital staff will need to request access to the “EHR Incentive Programs” application here and be approved by the Hospital’s Authorized Official.
What else do you need to know about registration?
Hospitals:
Hospitals that are eligible for EHR incentive payments under both Medicare and Medicaid should select “Both Medicare and Medicaid” during the registration process, even if they plan to apply only for a Medicaid EHR incentive payment by adopting, implementing, or upgrading certified EHR technology. Dually-eligible hospitals can then attest through CMS for their Medicare EHR incentive payment at a later date, if they so desire. It is important for a dually-eligible hospital to select “Both Medicare and Medicaid” from the start of registration in order to maintain this option.
Hospitals that register only for the Medicaid program (or only the Medicare program) will not be able to manually change their registration (i.e., change to “Both Medicare and Medicaid” or from one program to the other) after a payment is initiated and this may cause significant delays in receiving a Medicare EHR incentive payment.
Eligible Professionals:
Eligible professionals eligible for both the Medicare and Medicaid EHR Incentive Programs must choose which incentive program they wish to participate in when they register.
Before 2015, an eligible professional may switch programs only once after the first incentive payment is initiated. Most eligible professionals will maximize their incentive payments by participating in the Medicaid EHR Incentive Program.
The Electronic Health Record (EHR) Information Center is open to assist the EHR Provider Community with inquiries.
Hours of operation are:
8:30 a.m. ”“ 4:30 p.m. (Central Time) Monday through Friday (except federal holidays)
1-888-734-6433 (primary number) or 888-734-6563 (TTY number)
If you read my post on November 29th, you already know that CMS delayed pulling the trigger on January 1, 2011 to require PECOS enrollment for ordering and referring providers and enforcing nonpayment of claims that fail the ordering/referring provider edits.
CMS has just announced a new implementation date (calling it “a placeholder future implementation”) of July 5, 2011 – unknown.
As a refresher, the only providers who can order/refer Medicare beneficiary services are:
doctor of medicine or osteopathy;
dental medicine;
dental surgery;
podiatric medicine;
optometry;
chiropractic medicine;
physician assistant;
certified clinical nurse specialist;
nurse practitioner;
clinical psychologist;
certified nurse midwife;
clinical social worker
Claims that are the result of an order or a referral must contain the National Provider Identifier (NPI) and the name of the ordering/referring provider and the ordering/referring provider must be in PECOS or in the Medicare carrier’s or Part B MAC’s claims system with one of the above types/specialties.
The claim editing that will begin on July 5, 2011date not known will verify the ordering/referring provider on a claim is eligible to order/refer and is enrolled in Medicare.
The process to be used to determine if the ordering/referring provider on the claim matches the provider in the national PECOS file or in the contractor’s master provider file is as follows:
MCS (Multi-Carrier System) will verify the National Provider Identifier (NPI) of the ordering/referring provider reported on the claim against the national PECOS file.
If a match is not found, the MCS will verify the NPI of the ordering/referring provider on the claim against the MCS master provider file.
If a match is found, the MCS will then compare the first letter of the first name and the first 4 letters of the last name of the matched record.
If the names match, the ordering/referring provider on the claim is considered verified.
If you’ve not verified that your providers are properly enrolled in PECOS, you have yet another chance to get it figured out.
Here’s the Cheat Sheet:
Check to see if your provider is enrolled by reviewing the Ordering and Referring file found in the download section of the “OrderingReferringReport” tab (click here) on the Medicare Provider and Supplier Web Site. The report is currently more than 15,000 pages but you can view it on the screen.
If not enrolled, you can get your provider enrolled by paper or electronically. The Internet-based PECOS application is here.
After submitting an enrollment application via Internet-based PECOS, you must:
Print, sign and date (blue ink recommend) the Certification Statement(s), and
Mail the Certification Statement(s) and applicable supporting documentation to the designated Medicare contractor (no later than 7 days after you complete the online portion.)
NOTE: The Medicare contractor will not be able to begin to process your enrollment application until it receives a signed and dated Certification Statement.
For more detailed information on PECOS, click on the PECOS category on the right-hand side of this web page.