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Special Guest Author Amy Fehn: Understanding Medicare’s Revalidation Process for Medicare Enrolled Providers

Amy K. Fehn is a partner with Wachler & Associates, P.C.  Ms. Fehn is a former Registered Nurse who has been counseling healthcare providers for the past fourteen years on regulatory and compliance matters.  Ms. Fehn is a member of the American Health Lawyers Association, the State Bar of Michigan’s Health Care Law Section, and the American Bar Association’s Health Law Section where she participates on the ACO Task Force and the HITECH Task Force.  She can be reached at afehn@wachler.com.

Many health care providers have experienced confusion surrounding the revalidation request letters being sent by CMS contractors.  These letters are being sent by CMS’ contractors because of changes to the Medicare enrollment process mandated by the health care reform law, which requires all providers and suppliers who enrolled in the Medicare program prior to March 25, 2011 to revalidate their provider enrollment under new screening criteria. 

Medicare Administrative Contractors (MACs) will be sending the revalidation request letters through March 23, 2015.  The revalidation request basically requires providers to resubmit updated enrollment applications within sixty days of the postmark date of the request letter.  If the sixty day time frame is not met, a provider’s Medicare billing privileges may be deactivated.  Upon deactivation, providers will be given 120 days to submit the missing information.  Providers should also be aware that they can submit a written request for one sixty day extension if they need more time to complete the revalidation information.

Because it is so important that the revalidation be completed within the timeframes set forth by CMS, providers should educate office staff to be on the lookout for revalidation request letters.  CMS has indicated that the letters will be mailed in a different colored envelope so that they are more noticeable.  CMS has also stated that it will make two follow up phone calls if the revalidation documents are not received within the specified time frame.  However, there are still a number of reasons why providers and suppliers could miss the notification from CMS, including the possibility of wrong or outdated information.  Providers and suppliers who regularly deal with CMS also know that communications from CMS can be inexplicably lost in the mail on occasion.  Thus, to prevent the possibility of missing a revalidation notice, providers and suppliers would be wise to take proactive steps to check the CMS revalidation website at https://www.cms.gov/MedicareProviderSupEnroll/11_Revalidations.asp [1]  The “downloads” section of this website contains a list of providers/suppliers to whom revalidation notices have been sent.  It is important to note that providers cannot send in a revalidation until they have been sent the request letter.

Additional problems can arise when providers have not complied with CMS requirements to regularly update information such as address or ownership interests.  Because the enrollment form requires providers to include the effective date of any changes, the revalidation process can force providers to bring failures to update this information to the attention of CMS.  For example, providers are required to report a change in location or ownership within 30 days and other changes within 90 days.  Penalties for failing to update information can include deactivation of enrollment and assessments of overpayments.  Providers are cautioned, however, to be completely honest with regard to all information submitted on enrollment forms, including those submitted for revalidation because submission of false or misleading information can subject a provider/supplier to fines and even possible imprisonment. 

If not responded to appropriately, revalidation requests can quickly go from being a minor nuisance to being a major problem.  Providers and suppliers who have missed the revalidation submission deadline or have questions about how to complete the enrollment forms should consider contacting legal counsel for assistance.