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CMS offers Medicare revalidation Q&As

February 22, 2012

The U.S. Centers for Medicare & Medicaid Services (CMS) is proceeding with plans to revalidate all Medicare providers and suppliers who have not revalidated since March 25, 2011, so that all Medicare providers and suppliers are scrutinized under new screening requirements of the Affordable Care Act.

The following are selected questions and answers regarding the revalidation program posted on the CMS Web site (www.cms.gov).

Q: The owners of our medical group changed last year and the authorized and delegated officials have changed. Who should sign the revalidation-enrollment application that is to be submitted for our group practice? Will there be a penalty for not reporting the change?

Medicare requires (42 CFR 424.520(b)) that providers and suppliers inform Medicare of changes in practice, managing employees, and changes in billing services.

During provider revalidation Medicare Administrative Contractors (MACs) will verify and update the provider’s/ supplier’s enrollment record based on the information provided on the complete provider enrollment application whether submitted through Internet-based Provider Enrollment, Chain and Ownership System (PECOS) or paper form.

While there are exceptions, in general the person who signs the certification statement must be listed in section 6 and must be the current authorized official listed in section 6 of the CMS-855. The certification statement must be signed by an authorized official of the group practice.

The purpose of revalidation is to ensure all records are accurate and up to date.

Generally, the CMS does not contemplate taking administrative action against a provider/supplier for updating their records at this time even though it may not have been timely.

However, the CMS does reserve the right to take administrative action against those in certain situations where the failure to report the change would have caused the provider/supplier to be to ineligible for enrollment in the Medicare program.

Q: Will there be a way to revalidate without having to complete the entire enrollment application again?

Yes, if the provider is already enrolled in PECOS, you will be able to review your existing information online via the Internet-Based PECOS system (https://pecos.cms.hhs.gov/ pecos/login.do), make changes, and submit the revalidation application. If you do not have a record in PECOS, then you will be required to complete the entire 855 form.

Q: I plan on retiring shortly, do I still have to revalidate?

If you are asked to revalidate, please respond to the revalidate request.

If you have already retired and are no longer serving Medicare beneficiaries in any capacity, you should notify your Medicare contractor in writing so that your provider enrollment records can be updated to correctly reflect your retirement.

On your letterhead, submit a signed, dated notice to the Medicare Administrative Contractor (MAC) to notify them of your retirement.

This will help ensure that your Medicare enrollment record is updated correctly and in accordance with the information you have personally provided.

This will also help eliminate the potentially fraudulent use of your provider identification and enrollment information.

Q: Will I continue to receive Medicare payments while my MAC is processing my revalidation?

Yes.

Q: Will there be a gap in payment while my application is being processed?

There will be no gap in payment once your complete revalidation application is received by the Medicare contractors.

You must respond to the request to revalidate your provider enrollment within 60 days from the date of receipt of the application. Failure to respond to the request may result in deactivation of your provider identification number and enrollment billing privileges.

We strongly urge all providers and suppliers to carefully review their applications to make sure they are accurately completed, including appropriate signatures and required documents, before submitting them to the Medicare Administrative Contractors.

AOA members can access a complete list of CMS questions and answers related to the Medicare revalidation process on the AOA Web site Medicare revalidation page (www.aoa.org/Medicarerevalidation).

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