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Don’t Fall Into the Medicare Enrollment Revalidation Trap

By Jamie A. Klapholz | Categories: Articles, Health LawPrint PDF February 2017

As Medicare enters cycle two of provider and supplier enrollment revalidations, there is growing uncertainty surrounding an enrollee’s duty to monitor the Medicare Revalidation List for updated due date information to avoid deactivation of Medicare billing privileges. The Medicare enrollment revalidation requirement was established by Section 6401(a) of the Affordable Care Act. Enrolled providers and non-DMEPOS suppliers must revalidate their Medicare enrollment information approximately every five years (three years for DMEPOS suppliers), with the precise due date assigned by CMS two to six months in advance.

Though Medicare regulations indicate that enrollees are entitled to receive notice at least two months ahead of any revalidation deadline, CMS has taken the position that in the absence of such notice, an enrollee will still be subject to deactivation for a late revalidation submission. The rationale for this seems to be that due dates posted on the Medicare Revalidation List provide enrollees with constructive notice.

Within the last month, an official from one of the Medicare Administrative Contractors (MACs) serving Florida suggested that this opens the door for MACs to stop sending out revalidation notices altogether. Given that Medicare regulations provide CMS discretion to impose additional “off-cycle” revalidations, the prospect of rolling back the right to advanced notice is especially concerning. Providers and suppliers must remain vigilant in their Medicare Revalidation List monitoring and take note of its data update schedule.

Physicians and other individual practitioners would be wise to exercise caution when relying on delegated staff or consultants to properly submit their revalidations. In the last revalidation cycle, large organizations accepting reassigned benefits from multiple practitioners were hit especially hard with deactivations due to incomplete or inaccurate information. With suspension of MAC revalidation notices potentially on the horizon, it will be all the more difficult for large organizations to timely and accurately process all revalidations through a single point person.

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