Medicare Compliance & Reimbursement

Warning:  Carriers won't give you any leeway on enrollment jam.

If you don't have national provider identifiers (NPIs) for all of your providers, you may have trouble enrolling them in Medicare--even before an upcoming deadline.

Problem #1: The Centers for Medicare & Medicaid Services (CMS) announced that all Medicare enrollment applications must include NPIs for all providers. Starting June 5, you have to use the new CMS-1500 enrollment form, which CMS unveiled on May 1 and which includes a space for NPIs.

Problem #2: Several carriers started rejecting applications that lacked NPIs in early May, before the deadline. In some cases the rejections happened even for applications submitted in April, providers said. Carriers rejecting NPI-less applications include Trailblazer Health Enterprises, Empire Blue Cross/Blue Shield and First Coast Services Options, according to callers to Medicare's May 18 physician Open Door Forum (ODF).

Beth Israel Deaconess Physician Organization has over 100 applications that will need to be redone, according to Linda Guerra, director of provider and payor options. "Why is CMS is making this a requirement when [NPIs are] not actually required until May 2007?" she asked the ODF.

Similarly, all of Albany Medical Center's applications were rejected with no notice, due to the missing NPIs, one caller said.

Reason: CMS officials responded that they're requiring the NPIs for a few reasons. They need the NPI information early to develop their crosswalks from the old numbers. Also, having your providers' NPIs on file will give you an opportunity to test them over the next year to make sure you can get paid in May 2007.

What to do: CMS is instructing carriers to work with providers to fill in any information that's missing on application forms, including the NPI, CMS officials say. You shouldn't have to resubmit your application, they added.

"If you have doctors that will be graduating in July, those individuals can obtain an NPI today," one CMS official said. The doctors can provide you with that information in time for you to include it on their enrollment application, the official said.

"The timing is horrible" for this requirement, with so many doctors graduating from medical school and needing to be enrolled in Medicare, another caller said. "The communication process was horrible." CMS officials promised to address these problems in a timely fashion.

The upside: The new 855 enrollment forms that CMS has unveiled do a better job of explaining what documentation you need to submit with them, officials said.

Problem #3: The new enrollment form requires providers to be able to receive funds via electronic funds transfer (EFT). If you don't yet have EFT capabilities, you'll need to have them in place the next time you enroll a new doctor or renew a doctor's enrollment. [...]