2019 CMS Conference on Enrollment: What We Learned

The work that we do as provider enrollment and credentialing subject matter experts plays a crucial role to ensure that quality care is provided to the patients in our organizations. I still recall a time a few years ago when undergoing a minor procedure required general anesthesia. The last memory before dozing off was seeing the physician name which I recognized as a file that had been processed by our credentialing and enrollment team. It was reassuring to me that I was in good hands. Your organization and the patients which receive services from your providers benefit from the work you do every day. Patient Safety and Quality Care was a resounding message the 850 attendees heard at the 2019 National CMS Provider Enrollment Conference. The conference was kicked off by Zabeen Chong, Director of Provider Enrollment and Oversight Group for CMS and Charles Schalm, Deputy Director of Provider Enrollment and Oversight Group for CMS.

The conference was terrific and jam-packed with information which included updates, enhancement information on PECOS and information on what is coming. Many of us were waiting to hear when PECOS 2.0 would be launched. CMS reported that the anticipated launch of the new PECOS will be in 2020. The focus includes automation of functions, increased speed of application processing, decreased redundancy of data collected and increased alignment with Medicare and Medicaid.

There was acknowledgement of the benefit that one application for multiple enrollments would mean for organizations who enroll a provider in more than one state processed by multiple Medicare Administrative Contractors (MACs). While this is still a vision it is one that would undoubtedly improve enrollment processes. In the meantime there is no denying the benefit gained by enrolling providers utilizing PECOS.

As most of you know, Medicare is by far the largest health care payer in the United States with $632.9 billion Medicare expenditures and $552.3 billion Medicaid expenditures. There are a reported 2 million providers and 59 million patients who participate in Medicare and Medicaid. This article highlights new information and is a continued effort to communicate industry information to support your organization’s provider enrollment operations.

Policy Changes

October 2018 - Online applications must be e-signed or signature uploaded

• Why? Difficult for MACs to match paper signature to web submission
• Includes CMS-588 EFT and CMS-460 PAR Agreements

Late 2019 - No longer accept handwritten CMS-855 paper applications

• All paper applications shall be typed using the fillable CMS-855 form option
• MACs will return application if entire fields or sections are hand-written
• Could impact your effective date

April 2019 – Independent Diagnostic Testing Facility (IDTF)

• IDTFs are not required to report equipment that is being leased for less than 90 days
• Private practices providing IDTF services to ANY outside patients must enroll as an IDTF
• MACs will request a change of information application if they are notified that a Interpreting or Supervising Physician no longer provides services at an IDTF
• IDTF must remove the Interpreting or Supervising Physician from the IDTF enrollment and/or replace if that was the only physician on file
• Failure to appropriately update the IDTF enrollment may result in revocation
• The effective date for IDTFs undergoing a Change of Ownership (CHOW) that results in a new enrollment is date the business was transferred to the new owner

Policy Changes You May Not be Aware

CMS reminded the attendees that when submitting enrollment applications the following items are no longer required and provided clarification:

• Providers who are reassigned to a deactivated/revoked organization will have 90 days to submit a new practice location or reassignment before being deactivated.
• MACs should not call to speak directly to providers reporting a change in specialty.
• MACs should not request a diploma or degree unless education requirements cannot be verified online.
• MACs should not request a SSN card or driver’s license for identification.
• MACs should not request a phone, utility, power bill or lease to validate Legal Business Name (LBN) or “Doing Business As” (DBA).
• Lease only required to validate exclusive use of facility for PT/OT or ambulance suppliers leasing aircraft.
• MACs shall only request the dated signature of at least one authorized/delegated official for applications requiring development.
• MACs may accept a CP-575, federal tax department ticket, or any other pre-printed document from the IRS to validate TIN and/or LBN.

Effective April 1, 2019 Preclusion List

A summary of the Preclusion List and requirements is noted below and we recommend a review of details by reviewing the information on the CMS website.

Preclusion List Definition

A list of providers and prescribers who are precluded from receiving payment for Medicare Advantage (MA) items and services or Part D drugs furnished or prescribed to Medicare beneficiaries.

January 1, 2019

CMS made available the Preclusion List available to Part D sponsors and the MA (Part C) plans beginning JANUARY 1, 2019. To date CMS issued memos with guidance to MAOs, Part D Plan Sponsors and 1876 Cost Plans and Programs of Al-Inclusive Care for the Elderly (PACE) 11/02/2018, 12/04/2018, and 01/08/2019.

Why Was the List Created?

• To replace the Medicare Advantage (MA) and prescriber enrollment requirements.
• To ensure patient protections and safety and to protect the Trust Funds from prescribers and providers identified as bad actors.

Who is on the list? Those who…

• Are currently revoked from Medicare, are under an active reenrollment bar, and CMS has determined that the underlying conduct that led to the revocation is detrimental to the best interests of the Medicare program.
• Have engaged in behavior for which CMS could have revoked the individual or entity to the extent applicable if they had been enrolled in Medicare, and CMS determines that the underlying conduct that would have led to the revocation is detrimental to the best interests of the Medicare Program.

Provider Perspective and Communication

• Communication to provider/entities began January 1-31, 2019.
• Provider will receive an email and letter from CMS/Medicare Administrative Contractors (MAC) in advance of their inclusion on the Preclusion List.
• The email and letter will be sent to your Provider Enrollment Chain and Ownership System (PECOS) address if enrolled or National Plan and Provider Enumeration System (NPPES) email/mailing address if unenrolled.
• The letter will contain the reason you are precluded, the effective date of your preclusion, and provider’s applicable rights to appeal.
• CMS reports that updates to the Preclusion List will be made every 30 days around the first of the month.
• CMS will make available to Medicare Advantage plans and Part D plans access to the Preclusion List on a secure website.It was reported at the Conference that access to the Preclusion List would only be made available by CMS to Medicare Advantage plans and Part D plans.These plans would then determine if they will share the Preclusion List.
• A sample 2019 Part C and D Precluded Provider template to communicate to their members in the 11/02/2018 memo mentioned above.

April 1, 2019

• Medicare Part C: Medicare Advantage plans will deny payment for a health care item or service if the individual/entity is on the Preclusion List.
• Medicare Part D: Pharmacy will deny prescriptions at point of sale if the provider is on the Preclusion List.

PECOS Enhancement Updates

Upload Signature Documents

• Upload signature feature is now available and paper is not an option as a signature method
• Once the user selects “Upload”, they will be prompted to upload each signature document
• Users can upload a signature document either during the submission process or after submitting the application

Required Signer for Submission of Organization Enrollments

• Designated Officials (DO) are listed and available for selection as Authorized Signers.
• Designated Officials (DO) are included as required signers in Manage Signatures.

CMS 588, Electronic Funds Transfer Agreement (PDF) – Updated to Newer Version

January 2019 – New Specialties

• Medical Genetics and Genomics
• Undersea and Hyperbaric Medicine

January 2019 – CMS 855I Revised

Health and Human Services (HRSA) – Prepopulate FQHC Initial Enrollment Applications

• Effective April 2019
• HRSA will provide FQHC data to CMS – physical and mailing address
• CMS will upload data to PECOS for selection
• PECOS will pre-populate initial enrollment applications with the addresses