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.

CMS has fulfilled their promise to publish a list of providers and suppliers who were sent revalidation requests.

As you may be aware, the Affordable Care Act (ACA) requires all suppliers and providers who enrolled in Medicare prior to March 25, 2011 to undergo a new process known as revalidation. As part of revalidation, suppliers must:

• Submit a re-enrollment application (but not until requested to do so by the NSC),
• Pay an application fee, and
• Pass a series of enhanced screenings, background checks, and on-site visits designed to weed out illegitimate providers.

[For full details on what to expect during revalidation and how to submit your application, download the Are You Ready for Revalidation? Parts 1 and 2 digital recordings on our products page.]

While suppliers should not wait to submit important change of information updates to the NSC, such as a change in the types of products supplied or the opening of a new location, you must wait until you have been contacted by the NSC to submit a formal revalidation package (either via PECOS or a paper CMS-855S). Initially, CMS gave contractors until March 23, 2013 to send revalidation request letters to all currently enrolled suppliers and providers. However, after performing an assessment of the task at hand, CMS has extended that timeline to March 23, 2015.

The extended timeline does not necessarily mean your revalidation letter will be delayed, nor does it give suppliers who have already received one an extended response time! Letters are actively being sent to suppliers and providers as you read this. Upon receiving a request for revalidation you have only 60 days to submit an application before your billing privileges are revoked for non-response. If you have yet to receive your letter, we recommend you start preparing early by ensuring your business, county and state licenses are up to date. It is also a good idea to proactively register for access to the PECOS system (this process can take several weeks), which will allow you to see exactly what information the NSC has in your file and ensure that any necessary changes are submitted before revalidation catches you unprepared.

So how do you know if you’ve been sent a revalidation request letter? As mentioned at the top of this article, CMS has released a list of those suppliers and providers that have been sent revalidation requests through October 17, 2011. The list is available at: https://www.cms.gov/MedicareProviderSupEnroll/11_Revalidations.asp.

The list contains the names and NPIs of each supplier sent a request, and the date the letter was sent. It will download in a CSV format that may be opened using Microsoft Excel or other database programs. CMS plans to update the list on a monthly basis.  Suppliers who find their names on the list but who have not yet received their revalidation request letter should contact the NSC directly at 866-238-9652.

You may also use the link above to download a sample revalidation letter and get an idea of what to expect. While not yet final, CMS is considering sending out revalidation letters in an uniquely colored envelope to flag providers’ attention to this important request.

We all know that licensure requirements vary from state to state. While some states require licensure for a particular DME product, others do not. For this reason, it can sometimes prove challenging for DME suppliers to keep track of whether licensure is required for the products they provide in multiple service areas.  

Regardless of the challenges, to maintain compliance with Supplier Standard #1, suppliers must meet all applicable federal and state licensure and regulatory requirements. And with the National Supplier Clearinghouse (NSC) performing strict licensure verifications as part of the new revalidation process, it’s vital that you take a moment to verify that all required licenses are on file and up to date.

Recently, the NSC released a new, interactive database to help suppliers determine which products require licensure in each state to maintain Medicare billing privileges. Suppliers using the tool will be able to quickly determine:

• Whether a state requires licensure for a particular DME product,
• Whether the licensing requirement also applies to out-of-state suppliers and pharmacies, and
• Which agencies they must go through to obtain licensure.

In addition, the new database also provides links for suppliers to verify their licensure online (in cases where the licensing agency offers this service), along with any applicable notes on special licensure requirements or exceptions.

To begin utilizing the database, click here.

Suppliers are reminded that the database serves only as a guide, and it ultimately remains your responsibility to ensure you are in compliance with all state and federal regulations. In addition to product specific licenses, suppliers should also ensure that all applicable business, retail, pharmacy and sales tax permits are on file as required by your city, county and state.

You may be among an increasing number of nervous suppliers that recently started receiving an influx of unusual B7 denials on your Medicare EOBs. There is no need to panic yet. This is attributable to a system error that is incorrectly denying a large number of claims for not meeting accreditation standards. As we reported to you in the last few editions of Vista Notes, Medicare was to implement new edits beginning on July 5. 

The following groups of products were to be subject to the edits:

Diabetic supplies, Canes and crutches, CPAPs and accessories, Enteral Nutrients and supplies, Hospital Beds, Oxygen Equipment and Supplies, Respiratory Assist Devices, Support Surfaces: Pressure Reducing Beds/Mattresses/Overlays/Pads, Walkers, Wheelchairs – Complete Rehabilitative Power Wheelchair and Related Accessories, Wheelchairs – Standard Power and Related Accessories.

Apparently when the supplier validation files were sent to the MACs there was a critical error with the file that caused the edits to fire incorrectly. For now, there is no need to call your Accreditation Organization, MAC or the NSC. The MACs, CMS and the NSC are all working together to remedy the problem. 

As of the publication of this notice Jurisdiction D announced that they are currently pending all of these claims instead of letting them deny. We fully expect that other MACs will follow suit and that the MACs will ultimately reprocess all affected claims without the need for resubmissions or appeals. We will continue to keep you posted as additional information becomes available. 

7/19/11 UPDATE!

On July 19, CMS issued instruction to the MACs to temporarily deactivate the accreditation edit until a permanent fix is developed. At this time, claims should no longer be denying with B7 denials. Once resolved, the edit will be turned back on.

NHIC and CIGNA have both announced that they will automatically reprocess affected claims. We expect NGS and NAS to also follow suit.

A new Medicare enrollment fee is now in effect to cover the costs of the enhanced supplier screenings mandated in the Affordable Care Act (ACA). Effective March 25, 2011, all newly enrolling suppliers, revalidating suppliers, and/or suppliers opening a new location are required to pay a $505 fee upon submission of their Medicare (re)enrollment application (via the CMS-855S or PECOS). For suppliers opening or revalidating multiple locations, a separate $505 fee is required per location. The fee will be adjusted each year based on changes in the Consumer Price Index (CPI-U).

All currently enrolled suppliers are required to undergo re-validation (and pay an application fee) by March 23, 2012… even if your 3-year enrollment cycle is not scheduled to end until after this date. 

[Note: Many of you may have noticed that the NSC has basically stopped requesting re-enrollments due to a backlog of applications.  It now appears that the NSC will be forced to revalidate all suppliers within the next year.]

Coincidentally, the requirement for all suppliers to undergo revalidation no later than March 23, 2012 also falls during the same time that many suppliers will be simultaneously working towards renewing their accreditation. Accreditation was made mandatory in October of 2009, and suppliers must generally become reaccredited every 3 years.

Historically, suppliers have been instructed to wait until they receive a notice of re-enrollment letter from the NSC to being the revalidation process. At this time, the NSC has not released guidance on whether suppliers may voluntarily begin the reenrollment process prior to the March 23, 2012 deadline, or whether suppliers who are currently past due for revalidation may proactively start the process.

Full details on the new enrollment fee, including how the fee must be paid, are included in the April issue of  Vista Notes.

When you first enrolled in Medicare, you were asked to decide whether you wanted to be a participating (always accept assignment) or non-participating (chose whether to accept assignment on a case-by-case basis) supplier. As you may be aware, this choice is not set in stone and suppliers are able to update their participation status annually.

You currently have until the end of this year to change your participation status for 2011. Suppliers who wish to switch from participating to non-participating must submit a letter to the NSC on company letterhead that is signed by an authorized official. All requests must be received by January 1, 2011.Suppliers who wish to change their status from non-participating to participating must submit their request to the NSC via a CMS-460 form. 

If you have multiple locations, all locations will be assigned the same participation status. You may not have a different participation status for each location. If you do not wish to change your participation status, you are not required to notify the NSC.

Don’t Know Your Participation Status?

You can contact the National Supplier Clearinghouse at (866) 238-9652. You can also check your status online by visiting the www.medicare.gov/supplier  website and searching for yourself in the supplier directory. If you see a green P next to your company, you are designated as participating in the Medicare directory.

Participating vs. Non-participating

Full details on the different billing options available to participating vs. non-participating suppliers is included in the December 2010 issue of Vista Notes.

Effective September 27, 2010 DMEPOS suppliers looking to enroll or re-enroll in the Medicare program will face enhanced scrutiny from the NSC and CMS officials. On top of surety bond and accreditation requirements, CMS has issued a Final Rule, which implements several additional licensure and business operation requirements.

Some of the new requirements in the rule include:

• Suppliers of products that require a license in their state must have a certified W-2 employee on staff. (There are two exceptions to this rule.)
• Suppliers must maintain a physical facility on an “appropriate site” (as defined in the Final Rule) with access to the public.
• Suppliers may not use a cell phone, beeper or pager as their primary business phone. 

Additional regulations within the rule also limit which vendors oxygen suppliers may use to obtain oxygen and restrict the circumstances under which a supplier may contact a patient.

UPDATE!  On September 17, CMS released an additional proposed rule that will implement several provisions in the ACA related to Medicare enrollment screenings, application fees, compliance plans, moratoria and more. Provisions  addressed in the proposed rule include:

• How CMS will determine whether a supplier is at limited, moderate or high risk for fraud and the levels of screening they must undergo.
• How DME suppliers will be made to cover the costs of the screenings and how much you can expect to pay.
• Situations under which CMS may impose moratoria on entire categories of suppliers.

DMEPOS consultant Andrea Stark has reviewed all of the regulations in the Final and Proposed Rules and will be holding a detailed webinar to clearly explain what suppliers can expect on October 8, 2010 at 2:00pm EST. For more information, or to register for the event, visit the Seminars/Webinars page of our website.

H.R. 3363 is a bill to effectively delay the accreditation deadline for pharmacies who supply DME until January 1, 2010. The bill was introduced to the House on 9/29/09 and quickly passed with a voice vote on 9/30/09. On 10/01/2009 the bill was received by the Senate and was subsequently passed on October 5, 2009.

Update: On October 7, 2009, the bill was presented to the President for signature. As of October 12, 2009 the bill has not yet been signed into law.

While the bill seeks to delay the accreditation deadline for most pharmacies, those that wish to participate in the Competitive Bidding program will still need to meet Medicare’s accreditation requirement prior to placing their bids. Also, the bill only applies to organizations registered with the NSC as a pharmacy dispensing DMEPOS and not DMEPOS providers in general (even if they have a pharmacist on staff).

On 10/05/09, an HME News article reported that CMS is allowing pharmacies who have requested a voluntarily termination of their billing numbers or who have submitted an amended CMS-855S indicating they will no longer provide DME to continue billing Medicare, so long as the NSC has not already processed their application. Per the article, CMS has also asked the NSC to stop processing any further pharmacy applications for voluntary termination.

The article, entitled “House delays accreditation requirement for pharmacies” may be read in its entirety here.

MiraVista sent an inquiry to both CMS and the NSC requesting verification of these statements and further clarification. As of this posting, we have received no response.

Update: On October 09, 2009, the NSC released instruction to the DME MACs regarding H.R. 3363 and those pharmacies that submitted a voluntary termination prior to the original October 1 deadline. Bulleted points from the instruction have been copied and pasted below. To read the instruction in its entirety, click here.

• Pharmacies that were not accredited prior to the October deadline are not subject to the revocation of Medicare billing privileges at this time.
• Any pharmacies that submitted a voluntary termination that now wish to withdraw this request, must submit a letter to the NSC signed by the authorized official.
• The letter MUST be received by the NSC no later than October 23, 2009.
• Letters may be faxed to the NSC by geographic location.

The NSC included a map in its instruction to help pharmacies determine the appropriate fax number for their location. A copy of that map has been posted below:

© National Supplier Clearinghouse, 10/09/2009

National Supplier Clearinghouse Jurisdiction Map

 

Pharmacies on the East coast (Red) should fax termination withdrawal letters to: 803.382.2405.

Pharmacies in the Central region (Yellow) should fax termination withdrawal letters to: 803.382.2408.

Pharmacies on the West coast (Blue) should fax termination withdrawal letters to: 803.382.2406.

To read the full text of H.R. 3363, as well as track its progress, please visit this link:

http://www.washingtonwatch.com/bills/show/111_HR_3663.html#toc0.

Updates will be posted as they become available.

With the Accreditation and Surety Bond deadlines upon us, the NSC is receiving a heavy influx of calls from anxious providers wanting to check on the status of their applications. As a result, providers calling the NSC are finding themselves greeted not by a friendly customer service rep, but a continuous busy signal on the other end of the line.

To beat the busy signal, providers with questions on accreditation and surety bond requirements should try to find answers utilizing the NSC’s FAQ page or Accreditation and Surety Bond Exemptions chart.

For those checking on the status of their applications, the NSC is asking providers to allow their system at least two weeks to show mailed documents as received, prior to calling the customer service line.

Currently, the NSC has stated that it will not revoke the billing privileges of providers for which it has received accreditation information from their Accrediting Organization and a copy of their surety bond.

For more information, see MiraVista’s Important Accreditation Updates! news article below.

(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.