While preparing for a presentation in February, I was researching a web tool suppliers can use to check Medicare revalidation due dates. To understand the user experience directly, I performed an actual query for one of our data services clients. I was quite surprised to see that their revalidation was due in two days! Just to be sure everything was on track, I confirmed my client’s application status using the NSC application status tool.

The NSC returned nothing.

I immediately picked up the phone and called my client about the looming revalidation.

“Holy H***! We had no idea.”

Thankfully, he had 48 hours to process the necessary paperwork to keep the account active.

Because of the scare, I proceeded to check other clients’ accounts and a sick feeling came over me as client after client had pressing, and in some cases, already past, revalidation due dates.

A few of my clients were aware of the revalidation and had already submitted paperwork to the NSC. One or two had recently completed on-site inspections. But the vast majority were caught by surprise because they missed the written notifications from the NSC.

Why This Matters
 
If suppliers fail to respond to revalidation requests and the application due date lapses, the NSC deactivates Medicare billing privileges and discontinues payments until the revalidation process is completed. Deactivated providers are typically shut out for at least 45-60 days. Ouch!

What Suppliers Can Do to Avoid Deactivation

Suppliers should anticipate revalidations every three years. Make a quick check part of a quarterly or semi-annual routine.

When the CMS website has a future due date, suppliers can submit a revalidation application up to seven months before the documented due date. If a due date has recently passed, and your billing privileges are still intact, get the application on file ASAP. The NSC will not revoke active billing privileges if the supplier completes the revalidation process prior to revocation.

Submitting the Revalidation Application

Complete the following steps before the revalidation due date:

• Check to see if your revalidation is due by using the CMS tool.
• Pay the $586 fee here.
• Complete the online 855-S revalidation application through PECOS.
• Confirm the NSC is processing your (revalidation) application here.
  • Disclosure: The NSC status tool is not always accurate and does not update immediately.
  • When in doubt, call the NSC with questions at 866-238-9652.
• Call the NSC after 45 days, and then every two weeks thereafter, to ensure the NSC does not need more information to complete the revalidation. Failure to respond to NSC development requests in 30 days will result in supplier number revocation and will require a whole new application which will take up to 60 days to process.

My clients were fortunate. Everyone I spoke with was able to submit applications before the NSC terminated billing privileges. I hope as a result of this article you can avoid the panic altogether.

SOURCE LINKS
https://data.cms.gov/revalidation
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In case the celebratory fog of National Ballpoint Pen day caused you to miss it, registration for Round 2021 of the DMEPOS Competitive Bidding Program opened this week (June 10). Prospective bidders can log into the CMS Enterprise Portal until August 16, 2019 to add access to two applications: the DMEPOS Bidding System (DBidS) and Connexion.

Bidders will upload official bid application forms using DBidS. Connexion is the secure portal used to communicate with the Competitive Bidding Implementation Contractor (CBIC) and upload all supporting documents. All bid-related items must be submitted through these two platforms.

Suppliers that do not already have an active CMS account can register at any time.  In addition to bidding-related applications, suppliers use the CMS Enterprise Portal to access several familiar Medicare applications including myCGS, SPOT-FCSO, PS&R, Novitasphere, and HPG/HETS.

To add the bidding applications to your CMS Enterprise Portal account:

1. Validate access and match demographics exactly.
   1. Login to the CMS Enterprise Portal for the authorized official, backup authorized official, and end users for the company.
   2. Login to the PECOS account for the company.
   3. Make sure the following four identifiers match exactly across the CMS and PECOS accounts (applies to the authorized official and backup authorized official):
      1. Last name of the person registering.
      2. Social Security number.
      3. Date of birth.
      4. Email address.
2. Designate one authorized official from your PECOS CMS-855S enrollment application to act as the authorized official for bid registration purposes. 
   1. This individual must register first and then approve other users’ requests to access DBidS and Connexion.
   2. Bidders cannot share user IDs or passwords.
   3. Preselect who will serve as a back-up official.
3. Identify a PTAN for registration purposes. CMS will contract with the organization represented by the PTAN used for registration purposes:
   1. Get familiar with the official Legal Business Name (LBN) in PECOS and use it precisely and consistently - copy and paste for registration purposes to avoid errors.
      1. The LBN used for the DBidS and Connexion registration is the name that must appear on all other documents.
      2. The LBN on your company’s bid surety bond(s) must match the DBids and Connexion registration exactly.
      3. The LBN will auto-populate in the Business Organization Information section of Form A in DBidS.
   2. Sort out potential disqualification conflicts between commonly owned and commonly controlled organizations.
      1. Commonly owned and/or commonly controlled suppliers are prohibited from competing against themselves in the same competitive bidding area (CBA) and product category combination (competition). 
         1. Commonly owned suppliers are those where one or more of the entities has an ownership interest totaling at least five percent in the other(s). The term "ownership interest" is defined as "the possession of equity in the capital, stock, or profits of another supplier."
         2. Commonly controlled suppliers are those where one or more of a supplier's owners are also an officer, director, or partner of another supplier.
      2. When the bid window opens, suppliers must submit one bid (one PTAN designated as the primary location) that includes all commonly owned and/or commonly controlled locations that would furnish the lead item and all non-lead items in the same competition.

 
Don’t wait! Go ahead and verify your CMS registration and add the bid applications now so you have plenty of time to work out any issues that may impede your submission.

On May 2, CMS used its discretion to push back several key dates, giving suppliers a bit more time to prepare for bidding.  Earlier, the agency stated that the 2021 bid window would begin in June.

The updated timeline establishes:

• June 10, 2019 - Registration begins. (Registration will be open for 70 days)
• July 16, 2019 - Bid window opens. (Bidding will be open for 64 days)
• August 16, 2019 - Registration closes.
• August 19, 2019 - Covered Document Review Date.
• September 18, 2019 - Bid window closes.
• Fall 2019 - Preliminary bid evaluation notification
• Summer 2020 - Contracting begins.
• Fall 2020 - Suppliers announced.
• January 1, 2021 - Start of competition.
• December 31, 2023 - End of competition.

[Are you ready to have every group 2 support surface setup scrutinized by medical review? How about your referral sources? We know you are busy, so let us help you get ready for mandatory prior authorization.]

Along with the timeline announcement, the CBIC posted 18 new fact sheets and the remaining key resources to round out bid preparation and submission:

• Bid Preparation Worksheet and Utilization Reports
• Form A
• Form B
• Request for Bids Instructions

The CBIC is delivering several educational webinars that are available for registration:

• Bid Surety Bond and Lead Item Pricing (playback available now).
• Preparing and Submitting Financial Documents (playback available now).
• Registering and Submitting a Bid Part 1 (available June 11 at 3:00 PM EDT).
• Registering and Submitting a Bid Part 2 (available June 23 at 3:00 PM EDT).

 
With these final additions, suppliers now have all the critical details to successfully advance bid submissions.  
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With CMS launching a new mandatory prior authorization program for group 2 support surfaces in July, suppliers are understandably concerned about accommodating patients with immediate needs for pressure support, particularly upon hospital discharge.

Discharge planners typically start care coordination when the doctor signs the order to go home. Suppliers point out that the authorization process takes time. Suppliers must gather supporting documentation from multiple sources, and contractors will scrutinize requests before approving them.

Unlike many other conditions requiring home medical equipment, those treated with group 2 support surfaces rarely develop overnight or go unnoticed by admitting clinicians. To avoid delays in delivery and extended hospital stays, coordination among hospitals and suppliers must begin at admission for beneficiaries in need of pressure support.

Patients qualify for group 2 support surfaces via three pathways:

1. Multiple stage II ulcers on the trunk or pelvis, with evidence of prior treatment for at least a month using a Group 1 support surface and a comprehensive ulcer treatment program.
2. Large or multiple stage III or IV ulcers on the trunk or pelvis.
3. Surgical procedure for a myocutaneous flap or skin graft.

Suppliers should:

• Develop standard procedures to obtain prior authorizations.
• Educate hospital staff about the new mandatory prior authorization program.
• Request contact upon admission when ulcers or other qualifying conditions are present.

Though there is no published guidance at this time, authorizations should remain effective between one and six months after approval. 

If you provide group 2 support surfaces, join MiraVista’s Andrea Stark and Liz Beaulieu of HME News on June 6 at 1:00 PM (ET) for our webcast Get Ready for Mandatory Prior Auth of Support Surfaces.