Advanced Search

Practice Management Alert

Think CMS 855 Is Bad Now? One incorrect blank could mean federal regulators at your door.

Published on Sun Jun 01, 2003

Do you scrutinize your physician enrollment forms before you send them off to Medicare? If not, your practice might get a visit from the feds.

That's right, your practice could be subjected to site visits from federal regulators who want to verify the enrollment information you've provided on the CMS 855 form if an April 25 proposal from CMS becomes final. When CMS proposes a rule, it usually allows a comment period during which providers and other interested parties can weigh in with their thoughts on how the rule will effect them. In this case, you get until June 24 to comment. CMS will then consider the comments and publish the final version later this summer.

The 200-plus page rule is designed to establish a process that ensures qualified providers can participate in the program while bad apples are weeded out. The possibility that an incorrectly completed 855 form could trigger site visits from federal regulators worries some experts. It's not clear from the proposed regulation exactly what the "visitors" would be looking for, notes Robert Polglase, MD, JD, CEO of Strategem Group, Inc. in Augusta, Ga.

All of CMS's plans for 855 have the potential to throw a wrench in a provider enrollment process that's already often cumbersome and time-consuming for medical practices and billing companies, Polglase worries. CMS seems to recognize this problem as well, and notes that it's considering "a variety of ways" to make the process less painful for physicians'offices and other providers. If CMS'proposed enrollment reg flies largely as written  and the chances of that are good  physicians' offices will face a more convoluted Medicare enrollment process than ever before.

Here's a Sampling of What's to Come  

  • Cross yourT's and dot your I's on the 855. When submitting the CMS 855, the proposal says providers must be sure to include "complete and accurate responses to all information requested" in the sections that apply to your situation.

    Also be sure to submit any documentation CMS currently requires as identification, as well as any documentation currently required to establish a physician's eligibility to furnish services to Medicare beneficiaries.

        

  • Revisit your information every third year. Under the rule, providers will have to re-verify their enrollment information every three years. And if there are any changes to your information, you must report them within 90 days or risk having your Medicare billing privileged revoked, the rule proposes.

    Also, if your information hasn't changed and CMS hasn't heard anything out of you for three years, the agency proposes to contact physicians'offices to revali-date doctors'billing privileges. As part of this "routine revalidation," your office may or may not receive a visit from a Medicare rep  CMS reserves the right to conduct site visits as it sees fit.

    The agency also reserves the right to perform so-called "non-routine revalidation" if they are given reason to believe a physician's billing privileges should be questioned (for example, if beneficiaries have been complaining to CMS, or if he has been the target of an investigation, among other scenarios).

       

  • Respond promptly to requests for information. If physicians and other providers don't respond within 30 days to a request from CMS for additional documentation to support your enrollment, they will "immediately begin revocation proceedings," according to the proposed rule. If billing privileges are revoked, the physician will lose any and all provider agreements in affect at that time as well.

       

  • First-timers must act quickly or face rejection. If a physician enrolling in Medicare for the first time doesn't send in a complete CMS 855, or "fails to furnish missing information or any necessary supporting documentation as required by CMS" within 60 days of the agency's request for information, expect to have the 855 rejected. And if that happens, you have to start the process all over again, which will of course further delay the office's ability to submit claims for services that physician provides to Medicare beneficiaries.

       

  • Inactivity equals deactivation. Finally, under the proposal, CMS will deactivate a physician's Medicare billing number if she doesn't submit any claims for six months. That's a change from the current scenario, which says a number won't be deactivated until 12 months have passed with no claims being submitted. "We are including this reduction to the current requirement because we are aware of a number of program integrity issues related to inactive Medicare billing numbers," CMS explains. If your number is deactivated, you must submit a new CMS 855 to rejoin the game. 

    Editor's Note: To see the complete proposed rule, go to www.access.gpo.gov/su_docs/fedreg/a030425c.html. CMS is accepting comments on the rule until June 24, 2003.

     

     

     

    • Other Articles in this issue of

    Practice Management Alert

    View All