Did you see that CMS updated the Provider Enrollment FAQ in July affecting several flexibilities for DME suppliers? They modified:
On August 21, 2020, the NSC resumed enforcement for new and re-accreditation survey applications. Moreover, the agency is notifying suppliers that received extensions at the onset of the public health emergency (PHE) they have 30 days (from the date of the notice) to submit required documentation and resume the process. Those suppliers enrolled during the waiver period can expect to hear soon of rescheduled deadlines to produce documentation. Suppliers that do not comply risk loss of billing privileges.
Site Visits Resume
On August 6, 2020, the NSC announced it resumed site visits in accordance with the expiration of the standard 7 waiver. Standard 7 requires suppliers to occupy an appropriate site and post hours of operation.
Suppliers should ensure they:
Continued Waivers for On-Site Business Phone and Minimum Hours of Operation
Question 21 of the CMS FAQ contains incorrect information related to the enforcement of Standard 9 (primary on-site business phone, e.g. not a mobile or forwarded number) and Standard 30 (minimum hours of operation). The answer prematurely suggests CMS expired this waiver, when in-fact, the NSC continues to waive standards 9 and 30 for new and existing suppliers. As of this publication date, the CMS FAQ remains uncorrected.
Public Access Expectations Under Active Waivers
Despite continuation of the waivers for standards 9 and 30, the NSC expects suppliers to staff business phone lines during normal business hours. While the waivers persist, suppliers can forward calls to a remote office or cell phone, if necessary. As for retail hours open to the public, the NSC will not penalize locations with limited hours while waiver protection remains in force. Nonetheless, suppliers’ posted hours of operation should accurately reflect any temporary changes for the location.
Watch for Enforcement Changes
CMS continues to phase out waivers and flexibilities when the agency believes the climate no longer necessitates them. As such, suppliers should subscribe to NSC newsletters and check the NSC website for updated news on enforcement actions and waiver termination dates. We encourage suppliers to monitor conditions and self-impose a return to normal when feasible for each of their locations. When suppliers proactively phase out their reliance on waivers, they experience less disruption when the contractor announces a termination date.
SOURCE LINKS
https://www.cms.gov/files/document/provider-enrollment-relief-faqs-covid-19.pdf
https://palmettogba.com/palmetto/providers.nsf/DocsCat/Providers~National%20Supplier%20Clearinghouse~Articles~General~BS8KN64417?open
https://www.palmettogba.com/palmetto/providers.nsf/vMasterDID/BSPMJP5722?opendocument
newsletters
https://palmettogba.com/palmetto/providers.nsf/News_New?OpenView&RestrictToCategory=National%20Supplier%20Clearinghouse
- Question 20 (accreditation and re-accreditation).
- Question 21 (supplier standards 7, 9, and 30 for physical facility, business telephone, and minimum hours, respectively).
- Question 22 (site visits).
On August 21, 2020, the NSC resumed enforcement for new and re-accreditation survey applications. Moreover, the agency is notifying suppliers that received extensions at the onset of the public health emergency (PHE) they have 30 days (from the date of the notice) to submit required documentation and resume the process. Those suppliers enrolled during the waiver period can expect to hear soon of rescheduled deadlines to produce documentation. Suppliers that do not comply risk loss of billing privileges.
Site Visits Resume
On August 6, 2020, the NSC announced it resumed site visits in accordance with the expiration of the standard 7 waiver. Standard 7 requires suppliers to occupy an appropriate site and post hours of operation.
Suppliers should ensure they:
- Post accurate hours of operation visible to the public and site inspectors.
- Take care to answer the business telephone during those hours.
Continued Waivers for On-Site Business Phone and Minimum Hours of Operation
Question 21 of the CMS FAQ contains incorrect information related to the enforcement of Standard 9 (primary on-site business phone, e.g. not a mobile or forwarded number) and Standard 30 (minimum hours of operation). The answer prematurely suggests CMS expired this waiver, when in-fact, the NSC continues to waive standards 9 and 30 for new and existing suppliers. As of this publication date, the CMS FAQ remains uncorrected.
Public Access Expectations Under Active Waivers
Despite continuation of the waivers for standards 9 and 30, the NSC expects suppliers to staff business phone lines during normal business hours. While the waivers persist, suppliers can forward calls to a remote office or cell phone, if necessary. As for retail hours open to the public, the NSC will not penalize locations with limited hours while waiver protection remains in force. Nonetheless, suppliers’ posted hours of operation should accurately reflect any temporary changes for the location.
Watch for Enforcement Changes
CMS continues to phase out waivers and flexibilities when the agency believes the climate no longer necessitates them. As such, suppliers should subscribe to NSC newsletters and check the NSC website for updated news on enforcement actions and waiver termination dates. We encourage suppliers to monitor conditions and self-impose a return to normal when feasible for each of their locations. When suppliers proactively phase out their reliance on waivers, they experience less disruption when the contractor announces a termination date.
SOURCE LINKS
https://www.cms.gov/files/document/provider-enrollment-relief-faqs-covid-19.pdf
https://palmettogba.com/palmetto/providers.nsf/DocsCat/Providers~National%20Supplier%20Clearinghouse~Articles~General~BS8KN64417?open
https://www.palmettogba.com/palmetto/providers.nsf/vMasterDID/BSPMJP5722?opendocument
newsletters
https://palmettogba.com/palmetto/providers.nsf/News_New?OpenView&RestrictToCategory=National%20Supplier%20Clearinghouse
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