COVID-19 interrupted, paused, or otherwise impacted the provider enrollment process for a significant period of time, the same as with every other facet of healthcare and life. There were efforts by the Centers for Medicare & Medicaid Services (CMS) to expedite applications or allow for temporary enrollments in various cases to aid in the battle against COVID-19. In other cases, CMS slowed the enrollment process, temporarily suspending revalidations to allow efforts to be focused on other areas of healthcare and healthcare finance. More recently, there have been developments at CMS that you should be aware of regarding provider enrollment.
CMS has resumed its revalidation activities and processes. Consistent with overall revalidations over the last decade, this is coming in a phased approach for existing providers and suppliers that missed their revalidation due date during the Public Health Emergency (PHE). CMS has been mailing letters, and revalidations are well underway.
One plus side to this revalidation is that it does not apply to providers and suppliers that received temporary billing privileges through the Medicare enrollment hotlines. However, this was only a temporary stay. Since the PHE has been lifted, providers who were granted temporary billing privileges for COVID-19 will need to submit a complete CMS-855 enrollment application to establish full Medicare billing privileges. MACs will be sending out letters to specifically address these situations.
CMS will provide notice to providers and supplies in this first phase in two different ways:
Revalidation letters, which will be issued at least 3 months in advance of their due date to the correspondence address on file in your enrollment
The revalidation process is again fully intact. Failure to respond by the due date results in the deactivation of Medicare billing privileges. No payments will be made for services provided while billing privileges are deactivated.
Application fees were suspended during the PHE. As of October 2021, CMS resumed the collection of application fees in accordance with Medicare regulations. Please note that the application fee will continue to be waived for providers and suppliers who received temporary billing privileges through the Medicare enrollment hotlines. You can find the Application Fee Matrix here.
In conclusion, the COVID-19 pandemic undeniably had a profound impact on the provider enrollment process, just as it did on all aspects of healthcare and daily life. Now, CMS has resumed revalidation activities and application fees. This comes with a crucial reminder that failure to comply may result in the deactivation of Medicare billing privileges. Staying informed on these developments is critical for healthcare providers navigating the ever-evolving provider enrollment landscape. Please contact us with any questions or learn more about our healthcare accounting and consulting services to see how we might help your organization.
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Kirk Delperdang is a Healthcare Director at Lutz. He began his career in 1993. He provides healthcare enrollment services to clients with a focus on Medicare providers and reimbursement analyses. In addition, he is responsible for leading Lutz's cost report service offering.
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