On October 3rd, CMS announced that it is resuming Medicare revalidations of provider enrollment information in the PECOS system in October 2021.
If you are an existing Medicare provider and missed your revalidation due date because of the Public Health Emergency (PHE) deferral, CMS will be implementing these in phases. Effective October 31st, Medicare Administrative Contractors (MACs) and National Supplier Clearinghouses (NSC) will send notices for their first set of revalidations, due January 31, 2022.
Once all providers that missed their revalidations due to the PHE are up to date, schedules will go back to normal. CMS states that it will continue to be flexible in cases where providers experience delays due to PHI issues. However, it is still vital that you hit your revalidation deadline.
Here are some common Medicare revalidation questions that can help you through the process:
Q. How can you determine if your provider is due for a Medicare revalidation?
A. Revalidation deadlines are posted on the Medicare Revalidation List seven months in advance of their due date. This should give you enough time to comply. The site also provides directions below the search boxes to help you through the process.
Q. What happens if you miss your assigned provider’s Medicare revalidation deadline?
A. Although CMS has stated that it will be flexible due to the pandemic, its FAQs also make it clear that there will be no exemptions from revalidation and that the Agency does not grant deadline extensions. Accordingly, it is best NOT to miss your assigned Medicare revalidation deadline. Doing so can result in the deactivation of your standing as a Medicare provider. If this happens, you’ll need to start over again from scratch and submit a complete Medicare enrollment application as if you are a new applicant.
Q. How will you know when your provider is due for revalidation beyond looking it up on the Medicare Revalidation List?
A. Three to four months before your revalidation deadline, you should receive a notification from CMS – either by email or US postal mail. MACs and NCS also send notices. However, CMS makes it clear that you are responsible for keeping track of your revalidation deadlines and meeting them regardless of whether you receive your notification or not.
Q. If you haven’t received a notification, but the Medicare Revalidation List shows a due date for your provider, can you still process their revalidation?
A. If your provider’s deadline is within three months of your listed revalidation date, you are allowed to process it – even if you have not received a notice. However, you are not permitted to process your provider’s revalidation if the deadline is more than seven months away. If you do so, Medicare will return your revalidation, and you’ll have to process it again within CMS-allowed timelines.
Q. Are Medicare’s requirements for Fingerprint-based Criminal Background Checks (FCBC) back in place for enrollments?
A. CMS is resuming FCBC effective October 2021 only for providers and suppliers in high-risk categories. These include newly-enrolling Home Health Agencies, DMEPOS suppliers, Medicare Diabetes Prevention Programs, and Opioid Treatment Programs. If your provider has 5%+ ownership in a high-risk company, they must get a fingerprint background check. This includes any partnership interest (general or limited) as well. MACs will send letters requesting you to complete a fingerprint-based background check within 30 days of the date of the letter if you are required to supply one.
Q. If you received Medicare temporary billing privileges during the COVID downtime, are there any specific actions you must take now that enrollment has resumed?
A. If you previously received temporary billing privileges through the Medicare hotlines during the enrollment furlough, your revalidation will be delayed until the PHE is lifted. At that time, you must submit a completed CMS-855 enrollment application and be approved for full Medicare billing privileges. You will receive a notification from your MAC asking you to complete your application when it is due.
Q. When will applications be approved that were submitted to MACs before March 1, 2020, and are considered “pending?”
A. All pending applications received before March 1, 2020 will be processed within typical timeframes. Generally, electronic submissions are completed within 45 days of their receipt, and paper applications within 60 days.
For more information on how to improve your Medicare revalidations and other enrollment processes, check out Healthcare Training Leader’s Enrollment Training site. Just a few of the enrollment topics you’ll receive expert advice on include: Payer Delegation, Commercial Payers, Medicare PECOS (CMS Forms 855I and 855R), Surrogacy, CAQH, Multi-Practice, NPI Management, and Additions, Reassignments and Terminations.
Additional Medicare enrollment information: 2019-Novel Coronavirus (COVID-19) Medicare Provider Enrollment Relief Frequently Asked Questions (FAQs) Updated August 2021.
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