Under the Affordable Care Act, all Medicare providers and suppliers were required to revalidate their enrollment information under new enrollment screening criteria. The initial round of revalidations has been completed, and on March 1, 2016, CMS announced the beginning of Cycle 2 of the revalidation process. Cycle 2 requires all Medicare providers and suppliers to resubmit and recertify the accuracy of their enrollment information on a regular and periodic basis in accordance with 42 C.F.R. §424.515, which states that all enrolled providers and suppliers are required to revalidate their enrollment information every five years, or every three years in the case of a durable medical equipment supplier.
In connection with the commencement of Cycle 2, CMS also announced that it has implemented several changes to the revalidation process in an effort to make it more efficient and reduce provider and supplier burden. Two key areas which require the attention of healthcare providers include:
Recurring and Publicly Available Due Dates. CMS has established due dates by which each currently enrolled provider or supplier must revalidate its, his, or her Medicare enrollment information. Beginning with Cycle 2, the revalidation due date for a provider or supplier will always be on the last day of the month and the due date will generally remain the same for the provider or supplier for all subsequent revalidation cycles (i.e., June 30, 2016, June 30, 2021, etc.). A list of the current Medicare revalidation due dates, in addition to a revalidation due date lookup tool for all currently enrolled providers and suppliers, is available online. See https://data.cms.gov/revalidation
If the due date for a provider or supplier is more than six months in advance, it will display as “TBD.” CMS has stated that providers and suppliers with a TBD due date and who have not received revalidation requests from their Medicare administrative contractor (MAC) should not submit revalidation applications. If they do, those applications will be returned without processing.
Provider Enrollment Deactivation. A provider or supplier who fails to complete and submit its revalidation application by the due date or timely respond to all development requests from its MAC will likely have their billing privileges deactivated. In contrast with the initial round of mandatory revalidations, CMS has stated that if a provider’s or supplier’s billing privileges are deactivated for failure to comply with a revalidation requirement, the billing privileges will be reinstated once the provider or supplier submits the required application or information. The effective date of the reactivation of the provider’s or supplier’s billing privileges, however, will be the date on which the application or information was submitted. As a result, providers and suppliers who fail to comply with a request to revalidate their enrollment information will have a gap, and not just a delay, in their Medicare coverage. Given the potential ramifications of failing to respond, providers and suppliers will need to ensure that they regularly monitor the CMS revalidation due date database and respond to MAC requests for revalidation in a timely manner.
The revalidation process is most easily accomplished by utilizing the Internet-based PECOS location at https://pecos.cms.hhs.gov/pecos/login.do#headingLv1. However, in order to access this web portal, a provider or supplier will need its NPPES or PECOS username and password. If a provider is unable to find such information, it can be obtained via email if the provider/supplier has an email address that is listed on the CMS account or can provide some required identifying information.
CMS has made it clear that each provider/supplier is required to revalidate their entire Medicare enrollment record including all active practice locations and/or current reassignments. Revalidation of one provider number will not automatically revalidate all linked or reassigned provider numbers. Note also that if a provider of supplier needs to change or supplement any information in its provider enrollment record, the provider/supplier must submit a ‘change of information’ application using Internet-based PECOS or the appropriate CMS-855 form.
Brandon M. Schirg and W. Casey Dunlap practice healthcare law with Waller.
