Thursday Nov 12, 2015

Deadline extended for Medicare Part D prescribing

Physicians who prescribe medications to Medicare patients with Part D plans are getting more time to comply with new rules requiring that they either enroll in Medicare or have a valid record of opting out.

The deadline is now Jan. 1 to either enroll or opt out, although the Centers for Medicare & Medicaid Services (CMS) doesn’t plan to begin enforcing the new rules until June 1, 2016. This is the second time CMS has extended the deadline.

For those choosing to opt out, a word of caution: the opt-out period is for two full years and there is not an option for early termination. CMS has a very useful tool(www.cms.gov) to help you make this decision and to know what form to fill out.

If you are not sure if you are enrolled or have opted out, CMS has published a public file to check(data.cms.gov). You can use the “Find in this Dataset” box in the upper right-hand corner to search by your National Provider Identifier or your last and then first name. The list will also tell you if you are in an opt-out status. If you are not on the list, you can apply through the Provider Enrollment, Chain, and Ownership System (PECOS)(pecos.cms.hhs.gov). For information on how, there is a comprehensive step-by-step manual(www.cms.gov).

For more information on Part D, you can go to the Part D Prescriber Enrollment home page(www.cms.gov), which includes all of the above links as well as how to contact your local Medicare Administrative Contractor (MAC) for additional assistance.

– Barbara Hays, CPC, CPMA, is a Coding and Compliance Strategist for the American Academy of Family Physicians


Posted at 11:00AM Nov 12, 2015 by David Twiddy | Comments [0]

Friday Apr 24, 2015

Reminder: CMS will soon require enrollment for Part D prescribing

As we first noted last December, the Centers for Medicare & Medicaid Services (CMS) this year will begin requiring physicians who write prescriptions for Medicare Part D drugs to be either enrolled in Medicare or have a valid record of opting out.

We also noted that while the new policy is effective June 1, CMS has delayed enforcement until Dec. 1. If you aren’t currently enrolled in Medicare or do not have a valid opt-out affidavit on file you should submit an enrollment application or opt-out affidavit to your Part B Medicare Administrative Contractor by June 1. This will ensure that CMS has enough time to process the paperwork ahead of the Dec. 1 deadline and make sure your patients don’t have their Part D prescription drug claims denied.

To prepare prescribers and Part D sponsors for enforcement, CMS is using an online file to identify physicians and eligible professionals who are enrolled in Medicare in an approved or opt out status. The first iteration of the enrollment file is now available(data.cms.gov). CMS will update the enrollment file every two weeks through the Dec. 1 enforcement date.

Note that enrollment is not the same as participation. A physician can enroll in Medicare without being a “participating” physician.

For more information, including how to enroll online, CMS has published an article, “Provider Enrollment Requirements for Writing Prescriptions for Medicare Part D,”(www.cms.gov) through its MLN Matters information service. You can also find more information on the “Prescriber Enrollment Information” web page(www.cms.gov) on the CMS web site.   

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians


Posted at 11:00AM Apr 24, 2015 by David Twiddy | Comments [0]

Friday Dec 12, 2014

CMS enforcing new rules for Medicare Part-D prescribers – but gives more time

Physicians who prescribe Medicare Part-D drugs but do not participate in Medicare or have a valid record of opting out will face changes next year.

The good news is you'll have more time to accommodate the change.

The Centers for Medicare & Medicaid Services (CMS) earlier this year finalized a new rule under the Part-D program(www.federalregister.gov). The rule requires physicians and other eligible professionals who write prescriptions for Part-D drugs to:

• Be enrolled in Medicare in an approved status, or
• Have a valid opt-out affidavit on file.

The final regulation made the changes effective June 1, 2015. But CMS has announced that the deadline is being pushed back to Dec. 1, 2015.

Physicians who aren’t currently enrolled in Medicare or do not have a valid opt-out affidavit on file should plan on submitting an enrollment application or opt-out affidavit to their Part-B Medicare Administrative Contractor by June 1. This will ensure that CMS has enough time to process the paperwork ahead of Dec. 1 and will avoid patients’ Part-D prescription drug claims being denied.

For more information, including how to enroll online, CMS has issued an article, "Provider Enrollment Requirements for Writing Prescriptions for Medicare Part D(www.cms.gov)," through its MLN Matters information service.


Posted at 03:48PM Dec 12, 2014 by David Twiddy | Comments [0]

Thursday Oct 09, 2014

Medicare Part D policy changes could confuse patients

With the end of the year rapidly approaching, Medicare prescription drug plans are notifying their enrollees of changes for 2015. If an example shared with me by one family physician is any indication, those enrollees are getting some bad information.

Express Scripts included the following in its Medicare Annual Notice of Changes for 2015:

“Effective June 1, 2015, before your drugs can be covered under the Part D benefit, CMS [Centers for Medicare & Medicaid Services] will require your doctors and other prescribers to either accept Medicare or to file documentation with CMS showing that they are qualified to write prescriptions.”

This statement has its origins in section 6405(c) of the Affordable Care Act, which allows the Department of Health and Human Services to require that prescriptions for covered Part D drugs be prescribed only by a physician or other eligible professional who is enrolled in the Medicare program. CMS published its final rule on this matter(www.gpo.gov) in the Federal Register on May 23, 2014. In the final rule, CMS said that, beginning June 1, 2015, a prescriber of Medicare Part D drugs must have an approved enrollment record in the Medicare program or have a valid opt-out affidavit on file with one of the Part A/Part B Medicare administrative contractors (MACs).

Based on this information, the notice that Express Scripts (and others, possibly) is sending to Medicare patients is technically incorrect. CMS is not in the business of determining whether physicians are qualified to write prescriptions. By law, CMS is only requiring that physicians be enrolled with Medicare or otherwise have a valid opt-out affidavit on file with Medicare in order for Part D to pay claims for prescriptions written by them.

The vast majority of physicians are already enrolled in Medicare for purposes of billing their services under Medicare Part B. Among those who are not, many have a valid opt-out affidavit on file with the MAC in their area. Thus, it will be the rare physician whose Part D prescriptions are affected by this change in Medicare policy. With luck, this information will help you reassure any Medicare beneficiary concerned by what their Part D drug plan is telling them.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians


Posted at 02:56PM Oct 09, 2014 by David Twiddy | Comments [0]

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