The CMS Revalidation Project

The Affordable Care Act established a requirement for all enrolled providers/suppliers to revalidate their Medicare enrollment information under new enrollment screening criteria. The Centers for Medicare & Medicaid Services (CMS) has completed its initial round of revalidations and will be resuming regular revalidation cycles in March 2016.  Individual healthcare providers are required to revalidate their enrollment record(s) every five years.  DMEPOS suppliers are required to revalidate their information every three years.

Why do I have to re-validate my information?

The bottom line is that provider enrollment screening criteria has changed.  The screening process is much more rigid than past years and every participating provider must be screened under the new enrollment criteria.  Procedures for verifying addresses have been improved and strengthened in order to identify invalid addresses.  Requirements for keeping enrollment records up to date are more stringent and revalidation ensures each provider record is current and accurate.  Fingerprinting is now required on many types of providers as part of the enrollment process and revalidation will require affected providers to undergo that procedure.  Re-validation also improves the quality of the CMS particpating provider rosters by eliminating inactive providers.

Notice of Revalidation Due

In cycle 2 of the revalidation project, providers will have the advantage of knowing their revalidation due date.  CMS will publish revalidation due dates on its website that can be looked up by provider name and/or NPI.  The lookup can be found at https://data.cms.gov/revalidation.  In addition to the lookup table, the entire table of information can be downloaded for use with various programs to track the information.  Due dates will be on the last day of each month and will be published up to six months in advance.  It is important to note that CMS states that provider due dates will generally remain the same for subsequent revalidation cycles.  So, if you are a physician with a due date of 6/30/16, then after you revalidate this year your next due date will be 6/30/21.

Notices will be sent by MACs

Your local MAC will continue to send notices of revalidations due via postal mail and email.  Notices will be sent 2 – 3 months in advance of the due date.  Postal mail will be sent to at least two of your reported addresses:  correspondence, special payments and/or your primary practice address.  Email will be sent to the address pulled from prior application submissions and include the subject line: “URGENT: Medicare Provider Enrollment Revalidation Project”.

Deactivation

It is important to note that any provider or supplier that does not revalidate the enrollment file by the due date is subject to deactivation of billing privileges.  If you are deactivated for failing to revalidate your enrollment record, then you are required to submit a completely new application for participation in the Medicare program.  If your new application is approved and your billing privileges are reactivated, then you will retain your previous PTAN (Medicare ID) but your reactivation date is based on the receipt date of the new application.  Most importantly to note is that you will not be able to bill the Medicare program for services delivered during the period of inactivation.  This bears repeating with emphasis:

If you are deactivated from the Medicare program for failure to complete your revalidation process and you subsequently complete a new enrollment application for reactivation, then you will not be able to bill for services rendered during the period of inactivation.

It is important to note that during the revalidation process if you receive a development request on your application you must respond to that request within thirty days or your revalidation application will be rejected.

Use PECOS for Revalidation

As you revalidate your provider and/or supplier files, you are encouraged to use PECOS for application submission.  Using the online submission with e-signatures will help speed up the process.  Utilizing PECOS will also give you an advantage of somewhat the tracking progress of your application.  Once you submit your application through PECOS, you will need to follow up with your local MAC who is actually processing the application for monitoring real time status.  You will also interact with your MAC for any development items raised during your revalidation.  Overall though, a PECOS submission will be more efficient and timely than a paper application.

Summary

Failure to revalidate your provider and/or supplier files can be costly to your organization.  No longer can you reactivate a file and have it retroactively date back to the date you were inactive.  If your enrollment file becomes inactive, then you can no longer bill the Medicare program until you submit an entirely new application for reactivation.  During revalidation it is important that you submit revalidation for all of your practice locations and reassignments, and to respond to any development requests from your MAC.  Be proactive in managing the due dates of your revalidations to ensure you do not encounter any cash flow problems related to billing for Medicare services.

Read additional details on the latest MLN Matters publication.  https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/SE1605.pdf

About nCred

nCred is a leading national provider of healthcare credentialing services.  nCred has assisted thousands of providers and healthcare organizations throughout the country with the payer provider enrollment process.  The successful implementation of leading technologies combined with experienced credentialing staff produce excellent results for nCred clients.  Contact us today at (423) 443-4525 or fill out our request for information form to discuss how our services can benefit your organization.