The DME MACs are dismissing appeals submitted by third-party billing companies, not because the appeal itself is deficient, but because the submission lacks a written authorization for the billing company to act on the supplier’s behalf.
The requirement is not new, but feature improvements to the DME MACs’ web portals clearly tie uploaded appeals to the billing agent’s user ID. As a result, reviewers are more likely to check for the required authorization and dismiss those cases that do not include it.
Making the Appointment
Every appeal submitted on behalf of the supplier requires written authorization. To satisfy the requirement, the authorization must include:
The statement must describe the specific purpose of the appointment and the scope of the representation. For example:
The requirement is not new, but feature improvements to the DME MACs’ web portals clearly tie uploaded appeals to the billing agent’s user ID. As a result, reviewers are more likely to check for the required authorization and dismiss those cases that do not include it.
Making the Appointment
Every appeal submitted on behalf of the supplier requires written authorization. To satisfy the requirement, the authorization must include:
- The supplier’s:
- Name.
- Tax identification number.
- All applicable NPI numbers.
- A statement that both:
- Appoints the third-party to file the appeal on supplier’s behalf, and
- Authorizes the DME MAC to release protected health information (PHI) to the billing agent.
- Contact information for both the supplier and appointed third-party.
- Dates and signatures for both parties.
The statement must describe the specific purpose of the appointment and the scope of the representation. For example:
| I hereby appoint the above billing agency, and their employees, to act as my representative in connection with my claims and appeal rights under the Social Security Act. This agency is authorized to act wholly in my stead to:
In making this appointment, I further authorize appeal adjudicators to release identifiable health information to this agency when related to said appeals. |
The authorization does not have to be patient-specific. That means third-party agents can reuse a single statement for all appeals submitted within 12 months of the date of the last signature. For this reason, we recommend statements include all NPIs associated with the authorizing supplier.
Form CMS-1696
Form CMS-1696 Appointment of Representative satisfies the requirement. CMS-1696, however, is primarily designed for beneficiary representative appointments. Thus, there are confusing segments about fees and waivers that do not apply to billing agents for suppliers.
We recommend suppliers develop their own template with the required elements like this one we created for our (K)notes subscribers:
If you would like a copy of our example, just email us and we will be happy to send it to you.
SOURCE LINKS:
www.cms.gov/Medicare/CMS-Forms/CMS-Forms/Downloads/CMS1696.pdf
SOURCE LINKS:
www.cms.gov/Medicare/CMS-Forms/CMS-Forms/Downloads/CMS1696.pdf
RSS Feed