Deadline for enforcement of provider enrollment requirements for prescribing Medicare Part D drugs has changed

In 2014 CMS announced that all provider’s who write prescriptions for Part D drugs must have an approved Medicare enrollment record or a valid Opt-Out affidavit on file for their prescriptions to be covered under Part D.  CMS has announced a delay in
enforcement of this rule until February 1, 2017.  CMS suggests that providers not currently enrolled with the Medicare program submit either an enrollment application or opt-out affidavits to their Part B Medicare Administrative Contractors (MACs) by August 1, 2016 to allow time for MACs to process the applications.

The purpose of these rules are to ensure that Part D drugs are prescribed only by physicians and eligible professionals who are qualified to do so under state law and under the requirements of the Medicare program and who do not pose a risk to patient safety.  Prescriber’s who are determined to have a pattern of prescribing drugs that are abusive may have their billing privileges revoked under the rule.


To enroll with Medicare for the limited purpose of prescribing drugs, providers can submit a form CMS-855O or complete an application online using PECOS.  The form 855O is an abbreviated application for providers who desire an enrollment record for the sole purpose of ordering and referring for Medicare beneficiaries being treated.

Inpatient only providers who are employed by an institution must also have an enrollment record in order to prescribe Part D drugs.  Since institutions bill for such employed providers, these employed providers may not have a Medicare enrollment record.  However, for Part D drugs to be covered when ordered by an institution employed provider, that provider must have an approved enrollment record on file with Medicare.  The enforcement date for this category of providers remains June 1, 2016.

For more information about Medicare provider enrollment requirements for prescribing Part D Drugs, visit  Additional information on the change of enforcement date can be found in the Medicare Learning Network article SE1434.

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