"CMS Support: Answers referring to Revalidation"
Questions and Answers Regarding Medicare Revalidation 1. I heard the Medicare Administrative Contractors are revalidating Medicare provider enrollments. When should I submit my revalidation enrollment application? The MAC will notify you when it is time for you to revalidate your enrollment. You will receive a revalidation notification letter. Do not submit a revalidation application until you are requested to do so by your Medicare Administrative Contractor (MAC). Once you receive the request for revalidation from your Medicare Administrative Contractor, the quickest and easiest way to complete your application is through Internet-based PECOS (https://pecos.cms.hhs.gov/pecos/login.do). Paper 855 enrollment applications are also available at http://www.cms.gov/CMSFORMS/CMSForms/list.asp. You have sixty days from the post mark date of the revalidation notification letter to submit your completed paper or internet based PECOS electronic revalidation enrollment application. A list of providers and suppliers who have been sent requests for revalidation is available at: http://www.cms.gov/MedicareProviderSupEnroll/11_Revalidations.asp#TopOfPage. The list will generally be updated by the 20th of each month. 2. We are a pharmacy. What is the deadline for us to submit our revalidation? Will we get separate revalidation request for each entity and when should we pay the fee? The MAC, including the National Supplier Clearinghouse (NSC) will notify each supplier to revalidate. Suppliers and providers including pharmacies should not submit a revalidation application until requested to do so by the MAC or the NSC. In most instances each enrolled provider will receive a separate request to revalidate. Each enrolled institutional provider and supplier must submit a separate complete revalidation application. Each institutional provider or supplier--such as a pharmacy-- is required to pay an application fee. The fee must be paid before the revalidation application can be processed unless the institutional provider or supplier has submitted a request for hardship waiver. The evidence that the application fee has been paid or a request for hardship waiver has been submitted at the same time the revalidation application is completed and submitted to the Medicare Administrative Contractor (MAC). Newly updated instruction on payment of the application fee can be found at http://www.cms.gov/MLNMattersArticles/Downloads/SE1130.pdf . Providers, and suppliers who submit the application through the internet-based PECOS, will be automatically directed to the appropriate secure location to make the application fee payment. For providers and suppliers who submit paper enrollment applications must make their payment using the following secure URL: https://pecos.cms.hhs.gov/pecos/feePaymentWelcome.do. The application fee is $505 for revalidation applications received between March 23, 2011 and December 31, 2011. The application fee is $523 for revalidations applications received between January 1, 2012 and December 31, 2012. Each institutional provider must pay the application fee. 3. Do I need to revalidate now or wait until the Medicare Administrative Contractor (MAC) sends the request to revalidate? Please wait until CMS or a CMS Medicare Administrative Contractors has requested your revalidation before attempting to submit a revalidation application. Providers and suppliers can check to see if they have been issued a revalidation letter by viewing the list on our website. http://www.cms.gov/MedicareProviderSupEnroll/12_MedicareApplicationFee.asp#TopOfPage. The list will generally be updated by the 20th of each month. 4. We are concerned that we will not receive the revalidation requests that are mailed to the provider by theMAC, is there a way to get a list directly from CMS with the providers and suppliers that have been requested to revalidate? A list of providers and suppliers who have been sent requests to revalidate their Medicare enrollment is available at: http://www.cms.gov/MedicareProviderSupEnroll/11_Revalidations.asp#TopOfPage. The list will generally be routinely updated by the 20th of each month. 5. I recently enrolled in Medicare. Am I going to have to complete revalidation paperwork? Even if you recently enrolled, you may receive a request to revalidate your enrollment, since there are number of reasons your provider enrollment information may require an update. If you receive a request from your Medicare Administrative Contractor (MAC) to revalidate, you must do so. Once you receive the request for revalidation from your Medicare Administrative Contractor, the quickest and easiest way to complete your revalidation application is through Internet-based PECOS (https://pecos.cms.hhs.gov/pecos/login.do). Paper 855 enrollment applications are also available at http://www.cms.gov/CMSFORMS/CMSForms/list.asp. You have sixty days from the post mark date of the revalidation notification letter to submit your completed paper or internet based PECOS electronic revalidation enrollment application. You may complete the revalidation through internet- based PECOS (https://pecos.cms.hhs.gov/pecos/login.do) or you may submit the appropriate CMS 855 paper form available at https://www.cms.gov/medicareprovidersupenroll/02_enrollmentapplications.asp). If you believe you received the request to revalidate in error, you should contact the Medicare Administrative Contractor (MAC). 6. What hard-copy documentation must accompany the revalidation enrollment application? The documents that must accompany the 855 enrollment application or the internet based PECOS application form are specified within each application and may vary based on your provider or supplier type. However, for purposes of revalidation effort, CMS is moving away from requiring providers and suppliers to submit paperwork that has previously been submitted to the Medicare contractors if the information has not changed. For example a number of have previously submitted the CP-575 form. If nothing on this form has changed since it was last submitted to the Medicare contractor, the provider or supplier need not submit this information again with the revalidation application. However, if you are requested to do so by the Medicare contractor you should comply with that request. The contractor has the right to later ask for any information required, including previously submitted documents as needed to process the revalidation request. 7. Do I have to use the Internet-Based PECOS application to revalidate my enrollment? Internet-based PECOS (https://pecos.cms.hhs.gov/pecos/login) is the fastest way to review, update, and submit your revalidation enrollment application if you are already in the Provider Enrollment and Chain Organization System (PECOS). However, you are not required to use Internet-based PECOS application. You may complete and submit the appropriate 855 paper application form. 8. Do I have to submit a CMS 588 EFT form with the revalidation request? Medicare requires (42 CFR 424.510) that at the time of initial enrollment, during the course of making enrollment changes or revalidating, providers and suppliers must agree to receive Medicare payments through electronic funds transfer (EFT). As part of this revalidation effort, all suppliers and providers and supplierswho are not currently receiving electronic payment will be required to submit the CMS 588 EFT form. So, if you are not currently receiving Medicare reimbursement electronically you will be required to submit the 588 EFT form. 9. The owners of our medical group changed last year and the authorized and delegated officials have changed. Who should sign the revalidationenrollment application that is to be submitted for our group practice? Will there be a penalty for not reporting the ownership change? Medicare requires (42 CFR 424.520(b)) that providers and suppliers inform Medicare of changes in practice, managing employees, and changes in billing services. During provider revalidation Medicare Administrative Contractors (MACs) will verify and update the provider's / supplier's enrollment record based on the information provided on the complete provider enrollment application whether submitted through Internet -based PECOS or paper form. While there are exceptions, in general the person who signs the certification statement must be listed in section 6 and must be the current authorized official listed in section 6 of the CMS-855. The certification statement must be signed by an authorized official of the group practice. . The purpose of this revalidation is to ensure all records are accurate and up to date. Generally, CMS does not contemplate taking administrative action against a provider/supplier for updating their records at this time even though it may not have been done timely. However, CMS does reserve the right to take administrative action against those in certain situations where the failure to report the change would have caused the provider/supplier to be to ineligible for enrollment in the Medicare program. 10. Is a revalidation required if recent changes have been made and submitted by using 855 forms? Even if a provider recently submitted changes to their enrollment application, in most instances, the provider or supplier must still respond to the revalidation request. Providers and suppliers and suppliers will be sent written notification to revalidate. Providers and suppliers should respond to those requests within 60-days of the post mark date. If the provider questions the propriety of the request to revalidate they should contact the Medicare Administrative Contractor (MAC). 11. I am an Opt-out physician. Will I have to do anything with this revalidation enrollment to keep my status? Opt-out physicians who have provided their Medicare Administrative Contractors (MACs) with the appropriate information, including an affidavit that remains valid, are not required to revalidate. If you are unsure whether you have an affidavit on file with your contractor you should check with the Medicare Administrative Contractor (MAC). Contact information for each MAC can be found at: https://www.cms.gov/MedicareProviderSupEnroll/downloads/contact_list.pdf . 12. To what address are the Medicare Administrative Contractors mailing the revalidation request letters. During the first phase of revalidation which generally affects those providers and suppliers who are not in PECOS, two revalidation letters are sent. The first letter is directed to the "Special Payment" address and next is sent to the "Correspondence Address". If both are the same, the second letter will be sent to the practice address. 13. I am a provider practicing in several contractor jurisdictions. Can I submit one provider enrollment revalidation application? You will receive a separate request to revalidate from each of the Medicare Administrative Contractors (MACs) and you will need to respond to each MAC separately. Once you receive the request for revalidation from your Medicare Administrative Contractor, the quickest and easiest way to complete your application is through Internet-based PECOS (https://pecos.cms.hhs.gov/pecos/login.do). Paper 855 enrollment applications are also available at http://www.cms.gov/CMSFORMS/CMSForms/list.asp. You have sixty days (60 days) from the post mark date of the revalidation notification letter to submit your completed paper or internet based PECOS electronic revalidation enrollment application. 14. If the information in my revalidation is different than what you have on file about my practice location, authorized representatives, or other will there be any penalty for not reporting the change within the time frames required? The purpose of this revalidation is to ensure all provider enrollment records are accurate and up to date. Generally, CMS does not contemplate taking administrative action against a provider/supplier for updating their records even though it may not have been done timely. However, CMS does reserve the right to take administrative action against those in certain situations where the failure to report the change would have caused the provider/supplier to be to ineligible for enrollment in the Medicare program. 15. What will happen if I do not complete the revalidation? Failure to revalidate may result in a deactivation of your Medicare billing privileges. You must respond to the request to revalidate your provider enrollment within 60-days from the date of the receipt of the application. Failure to timely respond to the request to revalidate may result in deactivation of your provider identification number and enrollment billing privileges. 16. Will there be a way to revalidate without having to complete the entire enrollment application again? Yes, if the provider is already enrolled in PECOS, you will be able to review your existing information online via the Internet-Based PECOS system (https://pecos.cms.hhs.gov/pecos/login.do), make changes, and submit the revalidation application. If you do not have a record in PECOS, then you will be required to complete the entire 855 form. 17. Will the entire revalidation paperwork process be conducted by the MACs? Will CMS Regional Offices be involved? Yes, the Medicare Administrators Contractors will handle the revalidations. The CMS Regional Offices of the Divisions of Survey and Certification Divisions are not generally involved in the revalidation process, unless a State survey is required. It is expected that in most instances a new State survey is not required for revalidation purposes. 18. To whom does the revalidation effort apply? The Medicare enrollment revalidation effort over the next four years applies to all practitioners. Through the end of 2011, CMS is focusing the on revalidating providers and suppliers that were enrolled prior to March 25, 2011, providers and suppliers whose identification numbers are not in the Provider Enrollment Chain Organization System, and providers and suppliers in the moderate screening categories. 19. We have not received a revalidation request. Do we pay the $523 fee for 2012 now or do we wait until the MAC tells us to? Providers/suppliers who are subject to the fee should not submit the application fee nor submit a revalidation application until requested to do so by the Medicare Administrative Contractor (MAC). 20. Why do we have to revalidate when we have been billing and getting paid? Various sections of the Social Security Act and the Code of Federal Regulations require providers and suppliers to furnish information concerning the amounts due and the identification of individuals or entities who furnish medical services to beneficiaries before payment can be made. This helps protect the Medicare trust funds, the beneficiaries, and the vast majority of honest providers and suppliers from the few scrupulous providers and supplier intent on defrauding the program. Keeping your enrollment information up to date also helps prevent identity theft and use of your information without your knowledge. CMS is required under Section 6401(a) of the Affordable Care Act (ACA) to apply increased enrollment screening criteria to all sand suppliers. In order to meet these requirements, Medicare requires providers and suppliers to revalidate their Medicare enrollment information periodically. Providers and suppliers, including physicians, are required to revalidate their information every five years, while certain suppliers, including physicians who furnish durable medical equipment (DME), are required to revalidate their information every three years. Physicians will generally be asked to revalidate every 5 years. CMS is currently undertaking an "off-cycle" revalidation process now for most providers, meaning a provider or supplier may be asked to revalidate their enrollment sooner than three or five years. 21. Is the fingerprinting for the High Risk providers a part of the revalidation effort? As of December 31, 2011, fingerprinting is not part of revalidation. 22. Is the revalidation effort for individual providers/suppliers or groups? The revalidation effort will affect all suppliers and providers. 23. When are providers and suppliers required to revalidate? Providers and suppliers, including physicians, are required to revalidate their information every five years, while certain suppliers, including physicians who furnish durable medical equipment (DME), are required to revalidate their information every three years. CMS is currently undertaking an "off-cycle" revalidation process now for all providers, meaning a revalidation request could happen sooner than five years. Providers and suppliers should take action to revalidate their enrolment when requested to do so by their Medicare Administrative Contractor. 24. I plan on retiring shortly, do I still have to revalidate? If you are asked to revalidate, please respond to the revalidate request. If you have already retired and are no longer serving Medicare beneficiaries in any capacity, you should notify your Medicare contractor in writing so that your provider enrollment records can be updated to correctly reflect your retirement. On your letterhead submit a signed, dated, written notice to the Medicare Administrative Contractor (MAC) to notify them of your retirement. This will help ensure that your Medicare enrollment record is updated correctly and in accordance with the information you have personally provided. This will also help eliminate the potentially fraudulent use of your provider identification and enrollment information. 25. Will I continue to receive Medicare payments while my MAC is processing my revalidation? Yes. 26. My entity is enrolling/revalidating its enrollment as a federally-qualified health center (FQHC). Is it subject to the application fee provided for in 6028-FC, the recently published provider screening rule? Yes, a newly enrolling or revalidating FQHC is subject to the application fee. However, if your entity believes the application fee represents a significant financial hardship, it can request an exception through a hardship waiver request. Such requests are not granted automatically for any particular provider or supplier type; instead, such hardship exception requests are considered on a case-by-case basis. To request a hardship exception, you must submit documentation supporting the request at the time the enrollment application is submitted; otherwise, the application will be returned to you. While we do not prescribe particular documentation that must be submitted, the following would be helpful in helping us determine whether an entity should be granted a hardship exception from the application fee: (a) information on the income distribution of patients; (b) payor mix; (c) evidence that the facility is located in a medically underserved area and/or serves a medically underserved population; (d) amount of bad debt expenses; and (e) amount of charity care/financial assistance furnished to patients. Note that the request for a hardship waiver must be reviewed, and either approved or denied, before the review of the enrollment application will begin; this initial review can take up to 60 days. In addition, if the waiver request is denied, the provider must pay the application fee within 30 calendar days from the date of the waiver denial letter. Failure to do so will result in the denial of the provider's application or, in the case of a revalidation, the revocation of the provider's Medicare billing privileges. 27. I recently hired a new office manager. In addition, we will be moving next week. Should I submit that information now or wait to update this when I receive a revalidation request? There have been no changes to Medicare enrollment update filing timelines. Providers and suppliers should continue to submit routine changes-address updates, reassignments, additions to practices, changes in authorized officials, information updates and similar changes to their office or group practices-- as they always have done and in a timely manner. Providers and suppliers may continue to submit changes like address changes to Medicare no sooner than 30 days from when they expect to start billing at a new location. If the provider also receives a request for revalidation from the Medicare Administrative Contractor (MAC), the provider should separately respond to that request. If the provider or supplier has any questions about the need to complete the revalidation application, the provider or supplier should contact their Medicare Administrative Contractor (MAC). 28. For those providers and suppliers subject to site visits, who will conduct the site visits? The MACs have not issued any information on how that aspect of revalidation will take place. When will more information be forthcoming? Both Medicare Administrative Contractors (MACs) and CMS have issued guidance regarding the new provider screening levels. https://www.cms.gov/MLNMattersArticles/downloads/MM7350.pdf Announced and unannounced site visits are required prior to enrollment for initial enrollment, new practice locations and for revalidation for providers and suppliers in the moderate and high categorical screening levels. The site visits may be conducted by the MAC directly or a MAC subcontractor. In the future CMS will contract with a National Site Visit contractor to conduct all site visits. 29. We are a Hospital Based Multi-Specialty physician group practice, an Office Based Multi-Specialty physician practice and Single-Specialty physician group practice. Would we need to pay the application fee? Physician and non-physician group practices are not required to pay the application fee at the time of initial enrollment, revalidation, or when establishing a new practice address. However if any of the group practices or physician and non-physician practitioner also function as Durable Medical Equipment (DME) suppliers, they must pay a fee upon initial enrollment, revalidation or when establishing a new practice address. The application fee will be submitted along with the 855S application. 30. Which MLN Matter Article talks about the provider enrollment changes? The following links you directly to the article which addresses the Affordable Care Act related enrollment changes: https://www.cms.gov/MLNMattersArticles/downloads/MM7350.pdf . This MLN article also clarifies the revalidation effort has been extended through 2015 instead of 2013. Providers and suppliers will be contacted by their Medicare Administrative Contractors (MACs) when they are required to revalidate. Additionally, the following will take you directly to the MLN Matters Number: SE1126 Revised, "Further Details on the Revalidation of Provider Enrollment Information https://www.cms.gov/MLNMattersArticles/downloads/SE1126.pdf . 31. Will there be a gap in payment while my application is being processed? There will be no gap in payment once your complete revalidation application is received by theMedicare contractors. You must respond to the request to revalidate your provider enrollment within 60-days from the date of receipt of the application. Failure to respond to the request may result in deactivation of your provider identification number and enrollment billing privileges. We strongly urge all providers and suppliers to carefully review their applications to make sure they are accurately completed, including appropriate signatures, and required documents, before submitting them to the Medicare Administrative Contractors (MACs). 32. Does the provider have any say in determining in which screening category they are placed? The following link takes you directly to the MLN article which addresses the ACA related enrollment changes: https://www.cms.gov/MLNMattersArticles/downloads/MM7350.pdf . The revalidation application should accurately reflect the status of the provider/supplier. Information may be added, changed, or deleted on the revalidation application. 33. Please clarify how many application fees must be paid if there is one tax ID with 4 NPIs and 4 separate provider transaction numbers (PTAN). Each PTAN is a separate enrollment. Each PTAN is subject to a separate fee. Note: The application fee does not apply to physicians, non-physician practitioners, physician group practices, and non-physician group practices unless they are also Durable Medical Equipment Suppliers (DME). http://www.cms.gov/MedicareProviderSupEnroll/12_MedicareApplicationFee.asp#TopOfPage 34. I moved two years ago and never completed an application to change my address because all of my mail goes to a post office box. Will that create a problem for me? The purpose of this revalidation is to ensure all records are accurate and up to date. Generally, CMS does not contemplate taking administrative action against a provider/supplier for updating their records even though it may not have been done timely. However, CMS does reserve the right to take administrative action against those in certain situations where the failure to report the change would have caused the provider/supplier to be to ineligible for enrollment in the Medicare program. 35. With respect to the site visit, how can we determine which screening category we are in? How do we know if we have to pay the application fee? Beginning on March 25, 2011, Medicare will place newly-enrolling and existing providers and suppliers in one of three levels of categorical screening: limited, moderate, or high. The risk levels denote the level of the contractor's screening of the provider or supplier when it among other things, revalidates its enrollment information. Chapter 15, Section 19.2.1 of the "Program Integrity Manual" (PIM) provides the complete list of these three screening categories, and the provider types assigned to each category, and a description of the screening processes applicable to the three categories (effective on and after March 25, 2011), and procedures to be used for each category. Providers and suppliers who are in moderate screening categories are subject to announced and unannounced on-site visits that will be conducted by the Medicare Administrative Contractors (MACs).For purposes of CMS -6028 FC, specifically for purposes of this regulations, CMS has defined "institutional provider" to mean any provider or supplier that submits a paper Medicare enrollment application using the CMS-855A, CMS-855B (except physician and non-physician practitioner organizations), or CMS-855S or associated Internet-based PECOS enrollment application. Only institutional providers and suppliers are required to pay the application fee. For providers and suppliers who are required to pay the application, the application fee is $505 for applications received on or before December 31, 2011 and $523 for applications received January 1, 2012 through December 31, 2012. The following links you directly to the article which addresses the Affordable Care Act related to provider enrollment screening, provider screening levels, and the application fees. www.cms.gov/MLNMattersArticles/downloads/MM7350.pdf . andhttp://www.cms.gov/MedicareProviderSupEnroll/12_MedicareApplicationFee.asp#TopOfPage 36. Can you please provide the reference link that identifies those providers and suppliers who will be deemed as Moderate or High Risk? The following links you directly to the article which addresses the ACA related enrollment changes: https://www.cms.gov/MLNMattersArticles/downloads/MM7350.pdf . 37. Does the application enrollment fee apply to those who submit the 855 S? Yes. 38. What is Revalidation? Revalidation is the process by which CMS or its contractor requires a provider or supplier to certify the accuracy of their existing enrollment information with Medicare. 39. Am I required to receive Medicare reimbursement electronically through electronic funds transfer? The U.S. Treasury requirements mandate that most federal payments be made electronically. 40. What are the provider enrollment screening levels? Section 1866 (j)(2) of the Act requires the Secretary to determine the level of provider enrollment screening applicable to providers and suppliers according to the risk of fraud, waste and abuse to the program posed by particular provider and supplier categories. Medicare contractors will screen all revalidation applications based on CMS assessment of risk and assignment to a screening level of 'limited', "moderate," or "high". A complete description of the screening levels and procedures applicable to each category of provider specialty can be found in Section 15.19.2 of the Medicare Program Integrity Manual at http://www.cms.gov/manals/downloads/pim83c15.pdf .