On June 20, 2006, the new CMS enrollment policy for health care providers and suppliers will go into effect.  The policy will involve new enrollment requirements as well as procedures for updating and revalidating enrollment information.  All providers and suppliers, including those who have never completed a CMS-855 form, will be required to revalidate their information in the coming years.  CMS believes that its new policies will ensure that the Medicare program has adequate information on providers and suppliers who bill the program.  Existing providers are not required to take any action until requested to do so by CMS. 

       The new policy provisions include the following: 

• All those who have never submitted a CMS-855 form are required to do so.  For example, providers who have participated in Medicare prior to 1996 will not have an 855 on file.  CMS will notify providers who are required to make this initial filing;
• Once enrollment is complete, revalidations must be submitted every 5 years.  Medicare contractors will notify providers when their 5-year cycle starts, beginning with those who have never submitted a completed 855 form.  Once contacted, a provider has 60 days to submit the completed form with supporting documentation.  CMS will require a limited number of revalidations in FY 2006 and 2007, with increasing numbers after these dates.  Providers must comply with the new policies when submitting these forms in order to obtain and maintain Medicare billing privileges;
• f there are no changes at time of revalidation, the provider may simply sign, date and return the form;
• Providers MUST report any changes in previously submitted information (such as ownership, practice location and billing service changes) and provide supporting documentation within 90 calendar days after the change.  Failure to do so may result in revocation of billing privileges or deactivation.  Because revalidation is required every 5 years, it will be easy for CMS to determine when there has been a failure to update information;
• When a provider relocates and the carrier changes, the entire 855 must be re-submitted;
• If a provider does not submit complete documentation within 60 days after submission of an application or a request from CMS for missing information, rejection may occur.  This decision may not be appealed.  A new application must be submitted to re-apply;
• Enrollment may be denied for noncompliance with enrollment requirements;
• CMS may revoke a currently enrolled provider’s billing privileges for the same reasons that may justify denial of enrollment;
• Billing privileges may be deactivated if the provider does not submit claims for 12 consecutive months; and
• During a change of ownership, both the current owner and the new owner must complete and submit an enrollment application within 30 days after the transaction.  If the current owner fails to do so, it may be penalized, even after the date of ownership change. If the prospective new owner fails to submit a new application containing information on the new owner within 30 days after the transaction, CMS may inactivate the billing number.

       Online filing will not be in place until sometime in 2007, and for the present applications must be mailed to the carrier.  It is estimated that applications will take 60 days to process.  If you have any questions regarding new policy provisions or about completing the required enrollment forms, please contact one of KRHD’s health care attorneys.