Happy New Year my first blog for 2012( CMS Release New Changes to The Medicare Enrollement Forms)

If you have not submitted a Medicare enrollement application in a while, you are likely to notice some changes in the information you are required to provide. Effective July 1,2011, the Centers for Medicare and Medicaid Services (CMS) released newly revamped version of the Medicare enrollement application on Foms CMS-855A,855B,855R and 855I. In addition, CMS added a new form-the CMS-855O- for ordering and referring physicians and nonphysician practitioners (NPPs) who need to obtain a Medicare number for limited purposes.

The changes were issued as a follow-up to a final rule, published by CMS on February 2.2011, (at 76 FR 5862), pursuant to which CMS implemented various provisions of The Patient Protection and Affordable Care Act (PPACA). The final rule  addresses a number of topics, including new heightened screening procedures for providers and suppliers in the Medicare and Medicaid programs and Children's Health Insurance Program (CHIP).

The purpose of the CMS-855 Medicare enrollement application forms is to gather information from each provider and supplier that tells CMS who the individual/entity is, whether it meets qualifications to be a Medicare participating provider or supplier, where it provides services, who its owners and other key people are (officers, directors and managing employees) and other information necessary to establish correct claims payments. Many of the changes to the CMS-855 application expand on the "who" component by asking for more detailed information on the identity of the applicant, its qualifications to provide certain services and identity of its owners and key people.

Some of the notable changes on the Form CMS-855 application forms include the following (this list is not exhaustive):

Form CMS-855A

A check box was added to Section 2A that will identify whether a hospital has physician -owners. If yes a new six-page Attachement 1 have been added to capture very detailed information on the organization and individuals who have direct or indirect ownership or control interests in physician-owned hospitals. These changes were implemented in response to the new restrications made to the Stark Law's exception for physician ownership in hospitals enacted under the PPACA.

In section 2B, providers now have to indicate their year-end cost report date.

Section 5 and 6 of the Form, which report five percent or greater direct and indirect organizational and individual owners, as well as directors/officers and managing employees, have been completely revamped, including a new requirement that the provider report the exact percentage of all five percent or greater direct and indirect ownership interest and the effective date on which the ownership interests were acquired.

The revised CMS-855A now explicitly requires disclosure of any entity whose mortgage or other security interest in the provider is equal to five percent or more of the total property and assets of the provider.

This includes investements funds, holding companies banks and financial institutions, and charitable and religious organizations. In addition, the provider must submit an organizational diagram identifying all of the owning or controlling entities and their relationship to each other and the provider.

Section 5 and 6 now also require the provider identify any contractual services (including management and billing services) furnished by the provider's owners and managing organization/employees.

In addition institutional providers are now required to pay an application fee in connection with the initial Medicare applications, revalidations and the addition of practice locations. The application fee for 2011 is $505, which is subject to an annual cost of living adjustment. Institutions may submit a hardship exception request at the time of filing to request an exception from this fee.

Form CMS-855B

In section 2, ambulatory surgical facilities now have to provide information regarding their accreditation.

Also in Section 2, CMS now requests accreditation information for all groups and organizations that provide advanced diagnostic imaging services, including CT, MRI, nuclear medcine and PET.

In Section 6, individual owners, directors/officers, authorized officials and managing employees must now report their titles, place (state) of birth and effective date of ownership or control.

Form CMS-855I

In Section 2A, physicians and NPPs are now asked whether they will accept new Medicare patients. This information will be published in the " Medicare Physcians and Healthcare Provider Directory."

For those practitioners that for advanced diagnostic imaging services (CT, MRI, nuclear medicine and PET), information on accreditation for these modalities is now required.

In Section 6, managing employees must now report title, place(state) of birth and effective date of managing control.

Form CMS-855R

Suppliers that are terminating a reassignment must now list contact person

PECOS

Announcement from CMS:

All providers and suppliers who enrolled in the Medicare program prior to Friday, March 25, 2011, will be required to revalidate their enrollment under new risk screening criteria required by the Affordable Care Act (section 6401a). Providers/suppliers who enrolled on or after Friday, March 25, 2011 have already been subject to this screening, and need not revalidate at this time.

New Screening Criteria

In the continued effort to reduce fraud, waste, and abuse, CMS implemented new screening criteria to the Medicare provider/supplier enrollment process beginning in March 2011. Newly-enrolling and revalidating providers and suppliers are placed in one of three screening categories limited, moderate, or high each representing the level of risk to the Medicare program for the particular category of provider/supplier, and determining the degree of screening to be performed by the Medicare Administrative Contractor (MAC) processing the enrollment application.

Notices Will Be Sent to Providers/Suppliers

Between now and March 2013, MACs will be sending notices to individual providers/suppliers; please begin the revalidation process as soon as you hear from your MAC. Upon receipt of the revalidation request, providers and suppliers have 60 days from the date of the letter to submit complete enrollment forms. Failure to submit the enrollment forms as requested may result in the deactivation of your Medicare billing privileges. The easiest and quickest way to revalidate your enrollment information is by using Internet-based PECOS (Provider Enrollment, Chain, and Ownership System), at https://pecos.CMS.hhs.gov.

Fees Levied

Section 6401a of the Affordable Care Act requires institutional providers and suppliers to pay an application fee when enrolling or revalidating (institutional provider includes any provider or supplier that submits a paper Medicare enrollment application using the CMS-855A; CMS-855B, not including physician and non-physician practitioner organizations; CMS-855S; or associated Internet-based PECOS enrollment applications); these fees may be paid via www.Pay.gov.
In order to reduce the burden on the provider, CMS is working to develop innovative technologies and streamlined enrollment processes including Internet-based PECOS. Updates will continue to be shared with the provider community as these efforts progress.
For more information about provider revalidation, review the Medicare Learning Networks Special Edition Article #SE1126, titled Further Details on the Revalidation of Provider Enrollment Information.