CMS pushes back Medicare revalidation deadline to 2015

The AMA advocated for changes to the process of re-enrolling 1.4 million health professionals.

By Charles Fiegl — Posted Nov. 14, 2011

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Responding to pressure from physician organizations, the agency administering the Medicare program will extend by two years the deadline to re-enroll more than 750,000 physicians.

The move will provide the Centers for Medicare & Medicaid Services with more time as it embarks on the massive enrollment revalidation effort. The latest change to the timeline would allow for a smoother re-enrollment process, CMS said.

The Medicare agency had planned to re-enroll 1.4 million physicians, nonphysician practitioners and other health care professionals by March 2013. Physicians revalidating their enrollment records would be subjected to new screening controls required by the health system reform law.

The new standards are designed to prevent fraud in the Medicare system. But physicians are considered to be low fraud risks and would be subject only to license and identification verifications instead of the more stringent screenings required for device suppliers and home health firms.

The American Medical Association had requested the delay in September. In doing so, the Association asked CMS to re-examine the statute requiring the revalidation and to consider other changes to enrollment.

"We are very pleased that CMS has agreed to the two-year extension on the deadline to revalidate physicians' Medicare status," said AMA President Peter W. Carmel, MD. "This extension, recommended by the AMA, allows physicians to be one of the last groups who will have to face this time-consuming process."

The AMA and other health professional organizations said Medicare contractors would have been hard-pressed to revalidate 1.4 million enrollment records within an 18-month window. Contractors already process about 27,000 new enrollments and more than 30,000 billing reassignments each month. The organizations worried that the new revalidation effort would have led to application backlogs or other unintended consequences, such as doctors being inadvertently banned from the program.

The health system reform law says that by March 23, 2013, no physician or other health professional may be enrolled or re-enrolled in Medicare without going through the enhanced screening procedures. A Sept. 23 letter from the AMA to CMS referenced the law and noted that the section did not require the agency to complete the effort by the 2013 date. The law provided flexibility to implement the new screening methods from that date onward, the Association said.

However, the extra time given to physicians will not affect those doctors and practices who already have received a revalidation notice, CMS said. The physician still must meet the deadlines outlined in the revalidation letter he or she received. Failing to revalidate within the designated timeframe will cause a physician's enrollment record to be deactivated.

The first set of revalidation notices were sent to those who bill for Medicare services but are not in CMS' electronic enrollment record, the agency said. Typically, these recipients are doctors who have not updated their enrollment in several years. Medicare contractors searched enrollment databases to determine which physicians are not in the electronic system.

The Association had recommended that CMS exempt physicians from the revalidation effort altogether because they are low fraud risks to Medicare. The Medicare agency also should allow physicians to revalidate at any time, and not require doctors to print, sign and mail enrollment certification statements when applications are submitted online, the AMA said.

CMS declined to exempt physicians from the process, but it was willing to make other changes. A Nov. 4 CMS email on the revalidation states that physicians who believe they are not in Medicare's Provider, Enrollment, Chain, and Ownership system, or PECOS, can call their administrative contractors about revalidating.

The agency also has told the AMA that it will make improvements to the online enrollment system. New features will include electronic signatures, document upload capabilities, seamless password resets, enhancements for authorized officials, reassignment reports, new "My enrollments page" and "Fast track view" screens, and fewer duplicative document submission requirements.

CMS has said it will introduce these changes by the end of 2012.

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Basics of Medicare revalidation

All health professionals enrolled in Medicare before March 25, 2011, will be required at some point between now and March 2015 to revalidate their enrollment information with the program. Letters from Medicare contractors will outline how to re-enroll. A sample revalidation letter states that:

  • Physicians have 60 days from the date of the letter to complete and submit either a paper or online enrollment application.
  • Doctors must mail a signed certification letter to the contractor within 15 days of submitting an online application.
  • Equipment suppliers are required to pay a $505 application fee in 2011. Physicians, nonphysician practitioners and physician group practices are exempt from paying the fee.

Source: Sample revalidation letter, Centers for Medicare & Medicaid Services

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Not sure if you received a revalidation notice? Here's how to check

More than 105,000 physicians, nonphysician practitioners and facilities have been mailed letters from contractors since September asking them to revalidate their Medicare enrollment records, according to the Centers for Medicare & Medicaid Services.

CMS has compiled a list that includes those health professionals' names, national provider identifiers and the dates the revalidation requests were mailed. The list can be downloaded from the CMS website (link).

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