Andrea Stark

**This is a snippet from an article in the February 2013 edition of Vista Notes**

See: http://tinyurl.com/NSCOpenEnrollment

The most substantial provision affecting DME providers in the American Tax Payer Relief Act of 2012 (ATRA) is the provision to reduce all diabetic supplies (including strips, lancets and control solution sold in retail stores) to mail order rates effective 4/1/2013.  This equates to a 14% cut in the upcoming months.  More devastating than this is the next provision to subject retail diabetic supplies to national mail order rates as soon as that program goes into effect on 07/01/2013.  We know now that this will equate to a 72% cut across the board even if you did not participate in the bid program.

Medicare providers that are enrolled as ”participating providers” will most likely have to take the supplies off the shelf and cease selling them in their stores because the prices are not sustainable.  “Non-participating providers” will be left with no choice but to file claims non-assigned.  While non-participating providers can CHOOSE to accept assignment on a case-by-case basis, they also have the right to file claims on a non-assigned basis.  Non-assigned claims allow providers to collect the retail price up front and, after the claim is filed, Medicare remits payment to the beneficiary directly.  Beneficiaries will likely come out of pocket only a few times before they switch to a much cheaper, contracted, mail-order provider that will be forced to accept the cuts.

Because of the doc-fix provisions in ATRA and ensuing fee schedule changes for physicians, Medicare did extend the deadline to change participation status through 02/15/2013.  If you intend to change your participation status with Medicare, you must submit a letter signed by the Authorized Official to the National Supplier Clearinghouse and have it postmarked no later than today 02/15/2013.  Normally the Open Enrollment deadline would have already been closed effective 12/31/2012.  If you are a participating provider selling retail diabetic supplies and you do not want to accept assignment on these products, you may want to consider changing your status.  However, if you have multiple lines of business, such as a hospital-owned DME, the participation status must be the same for all entities… if the hospital is participating; the DME line of business must also remain participating.  To quickly see if you are listed as a participating supplier, visit this link, and enter the zip code where you are located along with a product you sell, then hit search.  If you see a green “P” next to your business, you are registered as a participating provider and must accept Medicare fee schedule rates on any covered product you sell to Medicare beneficiaries (unless you file the paperwork to change your participation status).  If there is no green “P” next to your business, there is no need to worry about the deadline and you already have the flexibility to choose assignment on a case-by-case basis. Your final decision to participate or not should be heavily weighted on your product mix and the Medicare fee schedule viability as it relates to your business.  For additional questions, arrange to speak with Reimbursement Consultant Andrea Stark at (803)-462-9959 ext. 246.

When revalidating through the electronic provider enrollment chain and ownership system (PECOS), you are highly encouraged to print a paper copy of your reenrollment application for your records. However, if you tried to do this recently, you may have noticed that not all of the information you entered into PECOS successfully printed. In fact, the form that prints may look somewhat different than the CMS-855S you are accustomed to seeing.

We have confirmed with CMS that there is a glitch in the PECOS system that occurs when suppliers try to print paper copies of their electronic reenrollment applications. Suppliers should note that this does NOT impact the information that is sent to the NSC. The information you enter into PECOS will still be successfully transmitted to the NSC, once your electronic application is submitted.

On one of the last screens displayed in the PECOS revalidation process, suppliers are given the opportunity to view and print a copy of the completed application. Clicking the print link should produce a prepopulated paper copy of the CMS-855S form that you may keep for your records. However, as of May 1, 2012, a glitch in the system is resulting in applications printing with incomplete fields and missing information. As previously mentioned, while this does create a bit of a headache for suppliers trying to print hard copies, if you can see the information in PECOS and everything looks correct online, it is safe to submit your electronic application to the NSC.

After a little digging, MiraVista was able to confirm that the glitch is the result of PECOS trying to print information to a new, draft version of the CMS-855S form that has not yet been released. You can identify whether PECOS incorrectly printed the draft copy of the CMS-855S by looking for an 04/12 revision date in the lower left-hand corner of each page. This version of the CMS-855S is not yet active, and it is our understanding that PECOS is not set to populate the revised fields in this form.

The active version of the CMS-855S form that should be linked to in PECOS (and that suppliers should use if they opt to submit a paper application) was last updated on July 2011 and can be identified by an 07/11 revision date in the lower left-hand corner of each page. This is the form PECOS is set to populate when printing hard copies of electronic revalidation applications.

We have informed CMS of the issue and have received confirmation that they are looking into a fix. A date has not yet been released for the implementation of the 04/12 draft version of the CMS-855S form. Look for full details on revisions made to the draft form in the June 2012 issue of Vista Notes.

DME suppliers who did not meet surety bond or accreditation deadlines were advised to voluntarily terminate their billing numbers to prevent being suspended from the Medicare program for a period of one year. Those suppliers who submitted a voluntary termination request did so with the understanding that billing privileges would be reinstated once they met all Medicare billing requirements and billing would be retroactive to the date of accreditation.

However, CMS recently threw a serious monkey wrench into the mix when they stated that suppliers would NOT in fact be able to bill retroactive to their date of accreditation, as previously thought. Instead, suppliers must now wait until their CMS-855S applications have been processed by the NSC to begin billing Medicare and will only be able to bill for services performed on or after the date their number is reactivated.

Several organizations, including AAHomecare, MAMES and the NSCAC are working towards a reversal of this policy. You can count on MiraVista to keep you posted on any changes.

(See: http://www.nscac.sitecreatorplus.com/f/nscac_august_2009_q&a_revisedfinal.doc)

Exactly 29,698 suppliers remain unaccredited as of August 24, 2009, according to a recent FAQ released by the National Supplier Clearinghouse Advisory Committee (NSCAC).

If you’re one of those nearly thirty-thousand, you’ve no doubt heard of CMS’ request for all suppliers who will remain unaccredited by the September 30^th deadline to voluntarily terminate their billing numbers by 10/01/2009. Whether you’ve decided not to partake in accreditation at this time or are in the midst of the accreditation process, voluntarily terminating your billing privileges will prevent you from being barred from the Medicare program for a period of 1-year and allow you to re-enroll once all Medicare billing requirements have been met (accreditation, surety bond, etc.). 

What happens if you voluntarily terminate your billing number?

Claims Processing:

Per the NSCAC, as long as a claim’s date of service is before the effective date of termination for your billing number the claim will still be processed. However, any claims submitted after the effective date of termination will not be paid and billing is not retroactive upon re-enrollment.

Patient Services:

Suppliers who voluntarily terminate their billing privileges must notify patients that they will no longer be participating in the Medicare program. The NSC has provided a sample letter to send to patients, which may be downloaded here.

Re-enrollment:

If you voluntarily terminate your billing number and opt to re-enroll at a later date, you will need to submit a CMS-855S.  Billing privileges will resume effective the date of compliance with both surety bond and accreditation requirements. 

What if you’re bonded/accredited and waiting on the NSC to update your status?

Initially, providers were asked to submit a CMS-855S to notify the NSC of their accreditation status. However, due to time constraints the NSC began allowing accrediting organizations to directly inform them of a provider’s accreditation.

Understandably, the NSC has become back-logged and there is concern among providers who have submitted an updated CMS-855S that their form will not be processed by 10/01/09. If you have this concern, you should contact your accrediting organization and request they directly notify the NSC of your accreditation status. At this time, the NSC has stated that it will not revoke the billing privileges of providers for which it has received a surety bond or information from their accrediting organization.

On August 17, 2009, CMS opened the registration window for competitive bidding. Providers who wish to place a bid will need to register with CMS’ Individuals Authorized Access Computer Services (IACS) system.  To register, please visit www.dmecompetitviebid.com, click on the Suppliers tab and then select Registration.

When registering, providers must appoint one authorized official (AO) and are encouraged to appoint one back-up authorized official (BAO) to manage their account. Both the AO and BAO must be listed as an AO on the provider’s CMS-855S enrollment form. AOs should register no later than September 14, 2009 and BAOs should register no later than October 9, 2009.

Any additional registrants beyond the provider’s AO and BAO are known as end users (EUs).  EUs have limited capabilities, such as filling out electronic bid forms, and may register until the close of the registration window on November 4, 2009 at 9:00pm EST. After this time, AOs may update company information, but no additional registrants will be accepted.

Prior to registration, it’s important that providers ensure their information is up-to-date and on file with the NSC and SSA. Information entered into IACS will be compared against information in the NSC (physical address, supplier number) and SSA (legal name, DOB, SSN) databases and must match exactly.

In most cases, the NSC is allotted up to 45-days to process all change of information (COI) requests. Per CMS, providers must wait 5 additional days after receiving confirmation from the NSC that their COI has been processed to update their information in the IACS system. However, the NSC has recently agreed to allow expedited faxed processing of sections 6 and 15 of the CMS-855S, when used to update AO information only. If you are only updating sections 6 and 15 of the 855S form, fax it to: 803.387.2407. For all other updates, the form must still be sent via standard postal mail.

For complete details on the registration process, bid forms, documentation requirements and bid rules, we invite you to attend Andrea Stark’s “Competitive Bidding: What to Expect this Time Around” webinar on August 27, 2009 at 2:00pm EST. You may register for the event or purchase a digital recording via the Seminars/Webinars page of this website.

(See: http://www.cms.hhs.gov/MLNMattersArticles/downloads/se0903.pdf)

CMS is asking any provider who has opted not to become accredited to voluntarily terminate their Medicare billing number.  Doing so will prevent Medicare from revoking the provider’s number on October 1, 2009 and barring them from the Medicare program.

Providers who wish to voluntarily terminate their Medicare billing privileges should submit an amended CMS-855S application to the NSC by September 30, 2009. To terminate their Medicare enrollment, providers must fill out sections 1B, 4A, 4B, 13, and 15 of the form.

Pharmacies that have opted not to become accredited but want to continue billing Medicare as a DME provider for drugs and biologicals only, must also submit an amended CMS-855S to the NSC. Pharmacies must remove DME items from the list of products being dispensed, and be sure to indicate which drugs and biologicals they will supply in section 2C of the form.

By: Michelle Duncan

Effective June 1, 2009 DMEPOS suppliers submitting applications to Medicare must use the revised CMS-855S form. Applications submitted after June first using the old 855-S form will be rejected.

The revised CMS-855S adds a 26^th Supplier Standard – “All DMEPOS suppliers must obtain a surety bond in order to receive and retain a supplier billing number” – and includes a new section for reporting surety bond information (Section 12).

Unless a supplier believes they are exempt (see: Surety Bond Final Rule: Multiple NPIs may Cost You Big Bucks article below), the following information must be reported in Section 12 of the revised form: 

• Surety Bond Company (the company who will be held liable for your bond)
  • The company’s Name and address (as reported to the IRS)
  • The company’s E-mail address, fax and phone number
  • The company’s Tax identification number (TIN)
• Insurance Agency / Broker (the agency/broker who issued your bond)
  • The agency / broker’s name and address (as reported to the IRS)
  • The agency / broker’s TIN
  • The name of the individual agent who issued your bond
• The Surety Bond amount, number, and effective date
• A copy of your surety bond must be submitted with the application. 

CMS encourages suppliers to begin using the revised CMS-855S immediately. Per the form’s instructions, you should submit a CMS-855S to Medicare if you are: 

• Enrolling in Medicare for the first time as a DMEPOS supplier.
• Currently enrolled in Medicare as a DMEPOS supplier and need to report changes to your business, other than enrolling a new business location (e.g., you are adding, deleting, or changing existing information under this Medicare supplier billing number). Changes must be reported within 30 days of the effective date of the change.
• Currently enrolled in Medicare as a DMEPOS supplier but need to enroll a new business location. This is to add a new location to an organization with a tax identification number already listed with the NSC. (This differs from changing information on an already existing location.)
• Currently enrolled in Medicare as a DMEPOS supplier and have been asked to verify or update your information. This includes situations where you have been asked to attest that your organization is still eligible to receive Medicare payments.
• Reactivating your Medicare DMEPOS supplier billing number (e.g., your Medicare supplier billing number was deactivated because of non-billing, and you wish to receive payment from Medicare for future claims).
• Voluntarily terminating your Medicare DMEPOS supplier billing number.

A full NSC Application Package, which includes the updated CMS-855S, is available via our products page. The package also includes: tips for filling out the new form, detailed instructions on how to document your existing TIN and NPI, comprehensive required documentation checklists, and more!

A copy of the CMS-855S is also available here.