Disruption to Medicare billing privileges can have a significant impact on a practice’s patient volume and income. Medicare requires certain providers and suppliers to revalidate upon request. Revalidation requires providers and suppliers to recertify the accuracy of their enrollment data. While enrolled providers and suppliers are required to report changes in enrollment data to Medicare, this is not always done. (See Medicare Reporting Obligations.)
With revalidation, Medicare seeks to ensure that the enrollment data is complete and up-to-date, including commonly inaccurate data regarding practice locations, reassignments, and final adverse legal actions.
Revalidation is required in order to maintain billing privileges. Failure to revalidate is grounds for revocation from the program. Likewise, providers or suppliers who report events that affect enrollment eligibility during revalidation may face revocation of their billing privileges.
Providers and suppliers enrolled in the Medicare program are subject to revalidation requests. Providers and suppliers that have opted-out of the program are not subject to revalidation. Providers or suppliers who are required to revalidate will receive a revalidation notice. Only providers or suppliers who receive notice of revalidation are required to revalidate.
Providers and groups are required to revalidate every five years. Suppliers of durable medical equipment, prosthetics, orthotics and supplies are required to revalidate every three years. However, CMS can conduct off-cycle revalidations. Off-cycle revalidation is often triggered by receipt of a complaint, local health fraud problems and other reasons that cause CMS to question a provider or supplier’s compliance with Medicare enrollment requirements.
Providers and suppliers required to revalidate will receive notice from their Medicare contractor (MAC). Notices are sent via email or mail to the provider or supplier’s special payment and correspondence address on file with Medicare. DMEPOS will receive notice via the National Supplier Clearinghouse (NSC). Providers and suppliers will have 60 days to complete the revalidation process. The due date will be in the revalidation notice. Providers and suppliers with current and upcoming revalidation requirements may also find their revalidation due date at the CMS Revalidation List.
Revalidation applications should be submitted via PECOS or mailing a copy of the enrollment application to the appropriate MAC. Providers and suppliers must complete the revalidation by the due date or they may face revocation of their Medicare billing privileges and other sanctions. Extensions will no longer be issued by MACs.
If the MAC reviews the revalidation application and determines that additional information is needed in order to process the revalidation, MAC will request such additional information from the provider or supplier.
Providers and suppliers must submit the requested information within 30 days of notice or their Medicare billing privileges will be temporarily suspended.
Upon completion of a revalidation application, MAC will review the revalidation application and determine enrollment eligibility. If MAC determines that the provider or supplier does not meet all requirements for enrollment, they can revoke the provider or supplier’s billing privileges.
CMS may inspect a provider, supplier or group to determine the accuracy of submitted enrollment information and compliance with enrollment requirements before revalidating. If CMS determines during an on-site inspection that the provider or supplier cannot furnish the required services or items, or has failed to satisfy any enrollment requirements, CMS can deactivate and seek revocation of the provider or supplier’s Medicare billing privileges. (See Medicare Revocations.)
Providers or suppliers who fail to timely revalidate may face the following sanctions:
Failure to submit a timely revalidation application or required information may result in deactivation of billing privileges. Providers or suppliers who are deactivated will need to submit a new full CMS-855 application to reactivate their enrollment.
Deactivation will result in a gap in coverage. Payment will not be made for services performed during the deactivation period. Any payments made will be subject to overpayment action. Medicare may also suspend payment on claims pending during the deactivation period.
Additionally, Medicare may seek revocation of a provider or supplier’s billing privileges for noncompliance found during a revalidation.
If Medicare revokes a provider or supplier’s Medicare billing privileges for failure to revalidate, the provider or supplier is barred from re-enrollment for one year. If CMS revokes a provider or supplier’s billing privileges for noncompliance and other issues discovered during revalidation, the provider or supplier may be barred from re-enrollment for up to three years. (See Medicare Revocations.)
The Medicare and Medicaid audit attorneys at Chapman Law Group have been helping health care providers for 35 years. We use our extensive experience for healthcare auditing services such as:
We work nationally with healthcare providers and professionals on Medicaid and Medicare audit matters. Our four offices are in:
Contact us today for a consultation.
"*" indicates required fields
After a RAC audit decision denied reimbursement for varicose vein procedures, our healthcare compliance attorneys helped a Michigan heart and vascular specialist practice draft a successful appeal.
When a physician got the wrong advice on a CPT code, leading to a Medicare and commercial payor audit, our health care lawyers stepped in to help.
Instead of potentially facing charges under the False Claims Act, the provider was paid the governmental incentive for properly achieving meaningful use or the exclusions thereunder.
In “Physician Guide to Basic Compliance Concepts,” Chapman Law Group’s national healthcare compliance attorneys cover how to spot and avoid healthcare fraud, handling investigations and audits, and keeping your staff in the right.
Can Medicare/Medicaid/government contractors seek debts after a bankruptcy filing? Yes, but it can be complex, and methods vary by jurisdiction.
Chapman Law Group’s Ronald W. Chapman Sr. and Juan Santos hosted a CLE session on DOH, DEA, Medicaid at the Florida Pharmacy Association Law & Regulatory Conference in Sarasota.
OIG guidance requires that health care entities institute sufficient controls to prevent fraud waste and abuse. This includes receiving reports of suspected health care fraud,
Michigan OFFICE
1441 W Long Lake Road
Suite 310
Troy, MI 48098
T. 248.644.6326
F. 248.644.6324
CALIFORNIA OFFICE
5250 Lankershim Blvd.
Ste. 500
North Hollywood, CA 91601
T. (818) 287-0576
FLORIDA OFFICES
6841 Energy Court
Suite 120
Sarasota, FL 34240
T. 941.893.3449
701 Waterford Way
Suite 340
Miami, FL 33126
T. 305.712.7177
Practice Areas
Attorneys
© CHAPMAN LAW GROUP. ALL RIGHTS RESERVED
