Family physicians who provide health care for Medicare patients and who enrolled in Medicare before March 25, 2011, will be required to revalidate their Medicare enrollment in coming months. That's according to a recent "special edition" article in CMS' online MLN Matters(www.cms.gov) publication for Medicare professionals.
CMS cautioned physicians to hold off on taking any action, however, until they receive notification about their individual revalidation from their Medicare administrative contractors. Beginning immediately and through March 23, 2013, Medicare contractors will send notices to affected professionals and suppliers notifying them that it's time to begin the revalidation process.
According to Cynthia Hughes, C.P.C., an AAFP coding and compliance specialist, the revalidation mandate is likely to irritate busy family physicians.
- Medicare participating physicians who enrolled before March 25, 2011, must revalidate their Medicare enrollment.
- Physicians should not act until they receive a notice from their Medicare contractor regarding revalidation.
- Revalidation notification will continue through March 23, 2013.
- The revalidation effort stems from language in the Patient Protection and Affordable Care Act that seeks to combat Medicare fraud and abuse.
"Many of our members just completed the re-enrollment process to ensure that they were entered into CMS' PECOS(pecos.cms.hhs.gov) (Provider Enrollment, Chain and Ownership System) for ordering and referring purposes or to add their national provider identifier number to the system," said Hughes. "This will be a duplication of effort for many physicians," she added.
Section 6401(a) of the Patient Protection and Affordable Care Act called for the establishment of certain procedures to screen physicians and other health care professionals who provide medical services to Medicare and Medicaid beneficiaries, as well as those who participate in the Children's Health Insurance Program, as a means of combating fraud. CMS published a final rule in the Feb. 2, 2011, Federal Register(edocket.access.gpo.gov) to implement those provisions and provided details in a March 23 CMS Change Request(www.cms.gov).
Subsequent to those changes, "CMS decided all Medicare providers have to re-enroll based on their new screening levels," said Hughes, adding that most physicians fall into the limited-risk category.
According to CMS, the most efficient way for physicians to submit their revalidation information is by using the agency's Internet-based Provider Enrollment, Chain and Ownership System, or PECOS(pecos.cms.hhs.gov). PECOS allows users to review and update information currently on file. To complete the process, physicians should
- submit the revalidation electronically;
- print, sign, and date the provided certification statement; and
- mail the statement and all required supporting documentation to the appropriate Medicare administrative contractor immediately.
Medicare contractors will process the revalidations in the same manner as previous enrollments. However, according to Hughes, CMS will provide contractors with a list of physicians and other health care professionals who have had a previous "adverse action," which includes exclusion from participating in Medicare, Medicaid, or other federal health programs; license revocation; or felony conviction.
"CMS will check new enrollments and revalidations against this list," said Hughes. "Physicians on the list could be subject to higher levels of screening -- including site visits -- to confirm that a valid practice is in operation," she added.
The topic of revalidation is on the agenda for the next CMS Open Door Forum scheduled for Sept. 20, 2011. Hughes urged family physicians to sign up to request notification(subscriptions.cms.hhs.gov) when information about that call is posted. Physicians will have an opportunity to comment and ask questions.