Provider Types Affected
Suppliers submitting claims to Medicare contractors (DME Medicare
Administrative Contractors (DME MACs)) for services provided to Medicare
beneficiaries
Provider Action Needed
This article is informational in nature and based on Change Request (CR)
6282 which incorporates recent regulatory changes and applicable instructions
for the National Supplier Clearinghouse – Medicare Administrative Contractor (NSC-MAC)
into the Medicare Program Integrity Manual (Chapter 10 (Healthcare
Provider/Supplier Enrollment)).
Background
The Medicare Program Integrity Manual (Chapter 10) specifies the
procedures Medicare fee-for-service contractors must use to establish and
maintain provider and supplier enrollment in the Medicare program. Change
Request (CR) 6282 incorporates National Supplier Clearinghouse – Medicare
Administrative Contractor (NSC-MAC) instructions into the Medicare Program
Integrity Manual, Chapter 10 (Healthcare Provider/Supplier Enrollment), Section
21 (Special Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS)
Instructions).
These NSC-MAC instructions evolved from recent regulatory revisions regarding
the following topics:
The timeframe in which providers and suppliers must furnish
developmental information to the NSC-MAC;
Effective dates of certain types of revocations;
Alert codes; and
Accreditation.
A complete description of these NSC-MAC instructions/topics is included as an
attachment to CR 6282, and the following provides a summary:
- The timeframe in which providers and suppliers must furnish
developmental information to the contractor
A Medicare contractor (including the NSC-MAC) may reject a
provider/supplier’s application if the provider/supplier fails to furnish
complete information on the enrollment application, including all supporting
documentation, within 30 calendar days from the date of the contractor’s
request for the missing information or documentation.The 30-day clock
starts on the date the pre-screening letter was sent to the
provider/supplier. If the contractor makes a follow-up request for
information, the 30-day clock does not start anew; rather, it keeps
running from the date the pre-screening letter was sent. To illustrate,
suppose that the contractor sent out a pre-screening letter on March 1 (thus
triggering the 30-day clock) that asked for clarifying information in
Sections 4 and 5 of the CMS-855B. (All supporting documentation was
provided.) The provider sent in most, but not all of the requested data.
Though not required to make an additional contact beyond the pre-screening
letter, the contractor telephoned the provider on March 20 to request the
remaining missing data. The provider failed to respond. The contractor can
reject the application on March 31, which is 30 days after the initial
request.
- Effective dates of certain types of revocations
A revocation is effective 30 days after the Centers for Medicare &
Medicaid Services (CMS) or the Medicare contractor (including the NSC-MAC)
mails the notice of its determination to the provider or supplier. However,
a revocation based on a Federal exclusion or debarment is effective with the
date of the exclusion or debarment. In addition, if the revocation was due
to the revocation or suspension of the provider/supplier’s license or
certification to perform Medicare services, said revocation can be made
retroactive to the date of the license suspension/revocation.
- Alert codes
The NSC-MAC will receive and maintain "alert indicators" based on
findings from the DME-MACs as well as on information received from
Medicare’s Program Integrity contractors.
- Accreditation
The NSC-MAC will follow the accreditation requirements in the Medicare
Improvements for Patients and Providers Act of 2008 (MIPPA). Individual
medical practitioners, inclusive of group practices of same, will not
currently require accreditation for enrollment. The practitioner types are
those specifically stated in Sections 1848(K)(3)(B) and 1842(b)(18)(C) of
the Social Security Act as Amended. In addition, the practitioner categories
of physicians, orthotists, prosthetists, optometrists, opticians,
audiologists, occupational therapists, physical therapists and suppliers who
provide drugs and pharmaceuticals (only) will not currently require
accreditation for enrollment.
Suppliers that fall in this subset who
provide other durable medical equipment outside of their specialty
are required to be accredited to bill Medicare as a DMEPOS supplier. DMEPOS
companies that are owned by any exempted individuals are NOT exempt from
accreditation. For example, physicians are exempt from accreditation
requirements for supplies they provide to their physician practice patients;
however, if a physician owns a DMEPOS company, that company is NOT exempt
from accreditation. Similarly, suppliers that provide only drugs and
pharmaceuticals are exempt from the accreditation requirement; however, if
the supplier provides equipment to administer drugs or pharmaceuticals, the
supplier must be accredited.
If a previously exempted supplier enrollment application was returned for
non-accreditation, the supplier must resubmit its CMS 855S Medicare
enrollment application to the NSC to obtain/maintain Medicare billing
privileges.
Additional Information
The official instruction, CR 6282, issued to your DME MAC regarding this
change may be viewed at
http://www.cms.hhs.gov/Transmittals/downloads/R280PI.pdf on the CMS website.
If you have any questions, please contact DME MAC at their toll-free number,
which may be found at
http://www.cms.hhs.gov/MLNProducts/downloads/CallCenterTollNumDirectory.zip
on the CMS website.
Effective Date: February 2, 2009; Implementation Date:
February 2, 2009
Incorporation of Recent Regulatory Revisions Pertinent to Suppliers of Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) Reference: Trans. 280, CR #6282, Pub. 100-08, MLN: MM6282