Medicare Makes Important Changes to Provider Enrollment Procedures

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Effective March 18, 2013, a number of important changes to Medicare provider enrollment process will go into effect. These changes are set out in Chapter 15 of the Medicare Program Integrity Manual. The changes, some of which are described in more detail below, cover a wide range of provider enrollment issues including: change requests; approval/rejection of enrollment applications; reporting of officers and directors/ board members of an enrolling provider; appeal timing; and the disclosure of partnership interests in the enrolling provider.

An important procedural change that may trip up unaware providers is that unsolicited additional information provided to a Medicare contractor by a provider following the submission of a previously submitted request will be treated and processed as a separate request, not as an update or addendum to an existing request.

With respect to new provider enrollment applications, Medicare contractors may reject an application where the certification page was signed more than 120 days prior to the date on which the contractor received the application, unless the provider or supplier provides a new, appropriately-signed certification statement within 30 days of the contractor’s request. The Medicare contractor will send a rejection letter no later than five business days after the contractor concludes that the provider or supplier’s application should be rejected. In the case of a rejected application, the Medicare contractor will either keep the original application and all supporting documents, or make a copy/scan of the application and documents and return the originals to the provider. If the Medicare contractor retains the original application, the provider or supplier may request a copy of the application be returned. If the application is approved, a letter will be sent no later than five business days after the Medicare contractor concludes that the provider or supplier meets all Medicare requirements and that the application can be approved, absent a CMS instruction or directive to the contrary.

Lastly, Corrective Action Plans (CAPs) shall be processed within 60 days of receipt, but the receipt of a CAP does not toll the filing requirements associated with a reconsideration request. Providers should still file an appropriate reconsideration request in addition to the submission of a CAP. Following approval of a CAP, the provider will be notified that the denial or revocation is rescinded and billing privileges are either restored or issued. The effective date of the restoration or issuance of billing privileges is based on the date the provider or supplier came into compliance with all Medicare requirements.