Enrollment

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The Centers for Medicare & Medicaid Services (CMS) has published a final rule with comment period establishing sweeping disclosure and monitoring obligations for providers and suppliers enrolled or enrolling in federal health programs, and expanding CMS’s authority to deny or revoke enrollment status.  In particular, the rule establishes an expansive new “affiliations” disclosure requirement that…

The Centers for Medicare & Medicaid Services (CMS) has once again extended for six months its “temporary” moratoria on the Medicare, Medicaid, and Children’s Health Insurance Program (CHIP) enrollment of new nonemergency ground ambulance suppliers and home health agencies (HHAs) in selected states, effective July 29, 2017. The moratoria on new HHA enrollment (including new…

The Centers for Medicare & Medicaid Services (CMS) is extending for six months its current moratoria on the Medicare, Medicaid, and Children’s Health Insurance Program (CHIP) enrollment of new nonemergency ground ambulance suppliers and home health agencies (HHAs) in selected states, effective January 27, 2017.  The temporary moratoria on new HHA enrollment (including new subunits …

On September 21, 2016, the House Ways and Means Committee approved H.R. 5713, the “Sustaining Healthcare Integrity and Fair Treatment Act of 2016” or “SHIFT Act.”  The primary focus of the SHIFT Act is to provide an additional delay in full implementation of the “25 Percent Rule” for long-term acute care hospitals (LTCHs).  The legislation also would tighten CMS’s authority to impose Medicare enrollment moratoria to prevent providers and suppliers from evading the moratoria by locating outside of moratoria areas. 
Continue Reading House of Representatives Approves Bill to Delay LTCH 25% Rule Implementation, Make Other LTCH Reforms, and Tighten Medicare Enrollment Moratorium Authority

CMS has announced a number of changes to its temporary Medicare enrollment moratoria for certain provider types in select geographic areas as a mechanism to address fraud, waste, and abuse. First, CMS is extending for six months and expanding statewide its current moratoria on the enrollment of new Medicare Part B nonemergency ground ambulance suppliers in New Jersey, Pennsylvania, and Texas, and enrollment of new Medicare home health agencies (HHAs) in Florida, Illinois, Michigan, and Texas. CMS states that the statewide expansion is intended to address situations in which providers circumvent a moratorium by enrolling in counties outside a moratorium and servicing beneficiaries within the moratorium area. Second, CMS is expanding these moratoria to Medicaid and Children’s Health Insurance Program (CHIP) enrollment. Third, CMS is lifting its current temporary moratoria on Part B emergency ground ambulance suppliers. These policies are effective July 29, 2016.
Continue Reading CMS Announces Changes to HHA/Ambulance Supplier Enrollment Moratoria, New Exception Process Demo

The House of Representatives has unanimously approved H.R. 3716, the Ensuring Access to Quality Medicaid Providers Act. The bill, which still awaits Senate consideration, would implement several OIG recommendations to improve CMS oversight of terminated providers and state screening of providers. Among other things, H.R. 3716 would require states and Medicaid managed care plans…

On March 1, 2016, CMS is publishing a proposed rule that would make a variety of changes to the Medicare, Medicaid, and CHIP provider and supplier enrollment requirements.  CMS believes that the proposal would assist in ensuring that individuals and entities posing risks to federal health care programs are removed or temporarily/permanently barred from participation in such programs.  Comments regarding the proposed rule will be accepted for 60 days after publication.

Notably, the proposed rule would implement an Affordable Care Act (ACA) provision requiring certain providers and suppliers to disclose if they have any current or previous direct or indirect affiliations (as defined in the rule) with a provider or supplier that:  has uncollected debt; has been or is subject to a payment suspension under a federal health care program; has been excluded from Medicare, Medicaid or CHIP; or has had its Medicare, Medicaid or CHIP billing privileges denied or revoked.  Under the ACA, the Secretary is permitted to deny enrollment based on an affiliation that the Secretary determines poses an “undue risk” of fraud, waste or abuse.  The proposed rule enumerates the factors that would be considered in such a determination, such as the duration and extent of the affiliation and the nature of the affiliated party’s disclosable event.  CMS proposes a 5-year “look-back” period for determining previous affiliations (as of the date the enrollment application is submitted).

The proposed rule also would authorize the Secretary to: 
Continue Reading CMS Proposes Program Integrity Enhancements to the Provider/Supplier Enrollment Process, including New Affiliated Provider Disclosure Requirements

CMS published a notice February 2, 2016 announcing an additional 6-month extension of its current temporary Medicare enrollment moratoria for new ground ambulance suppliers and home health agencies (HHAs), subunits, and branch locations in designated metropolitan areas.  The moratoria, which also apply to enrollment in Medicaid and the Children’s Health Insurance Program, apply to:

  • New

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On December 4, 2015, CMS published a final rule that extends enhanced federal funding for the design, development, installation, or enhancement of Medicaid eligibility and enrollment systems. The rule also updates standards for Medicaid Management Information Systems (MMIS). According to CMS, the final rules will help states automate the application and renewal process, improve…

CMS has announced that the CY 2016 provider enrollment application fee is $554, up slightly from $553 in 2015. This application fee is required for institutional providers that are initially enrolling or revalidating enrollment in the Medicare or Medicaid program or the Children’s Health Insurance Program (CHIP) or adding a new Medicare practice location on…

On November 18, 2015, the House Energy and Commerce Committee approved several public health policy bills. Two approved bills pertain to the Medicaid program:

  • HR 3716, the Ensuring Terminated Providers Are Removed from Medicaid and CHIP Act – to implement several HHS OIG recommendations to improve CMS oversight of terminated providers and state screening of

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The Government Accountability Office (GAO) has issued a report examining the extent to which CMS’s enrollment screening procedures are designed and implemented to prevent enrollment of ineligible or potentially fraudulent Medicare providers. The GAO identified weaknesses in CMS’s verification of provider practice location and physician licensure status that have allowed potentially ineligible providers and suppliers…

CMS has announced another 6-month extension of its current temporary enrollment moratoria for new ground ambulance suppliers and home health agencies (HHAs), subunits, and branch locations in designated metropolitan areas. The moratoria, which affect enrollment in Medicare, Medicaid, and the Children’s Health Insurance Program, apply to:

  • New ground ambulances in the Houston and Philadelphia

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CMS is extending — for another 6 months — its current enrollment moratoria for new ground ambulance suppliers and home health agencies (HHAs) in designated metropolitan areas. The moratoria, which affect enrollment in Medicare, Medicaid, and the Children’s Health Insurance Program, apply to new ground ambulances in the Houston and Philadelphia metropolitan areas and new HHAs…

On December 5, 2014, the Centers for Medicare & Medicaid Services (CMS) published a final rule that expands the circumstances under which it may deny or revoke the Medicare enrollment of entities and individuals on program integrity grounds, effective February 3, 2015. Among other things, the final rule: allows CMS to deny enrollment to providers, suppliers, and owners that previously were affiliated with an entity with unpaid Medicare debt; allows CMS to deny or revoke enrollment if a managing employee has been convicted of certain felony offenses; and enables CMS to revoke Medicare billing privileges for a “pattern or practice” of improper claims submissions. CMS is not finalizing its proposal to dramatically increase the potential reward for individuals who provide tips leading to the recovery of Medicare funds.
Continue Reading CMS Finalizes Rule to Strengthen Medicare Provider Enrollment Regulations and Permit Revocations for Patterns/Practices of Improper Claims Submissions; Defers Expanded Awards for Medicare Fraud Tipsters

CMS has announced that it is delaying a provision of its 2015 Medicare Advantage/Medicare Part D final rule, published on May 23, 2014, that requires physicians and other eligible professionals who prescribe Part D drugs to be enrolled in Medicare (or have a valid opt-out affidavit on file) for their prescriptions to be covered…

Today CMS published a notice announcing that the CY 2015 provider enrollment application fee is $553, up from $542 in 2014. This application fee is required for institutional providers that are initially enrolling or revalidating enrollment in the Medicare or Medicaid program or the Children’s Health Insurance Program (CHIP) or adding a new Medicare…

CMS’s long-awaited fingerprint-based background check screening process is underway for certain “high-risk” providers and suppliers participating in federal health care programs (specifically, Medicare, Medicaid, and the Children’s Health Insurance Program). Under CMS regulations, individuals who maintain a 5 percent or greater direct or indirect ownership interest in a provider or supplier in the high risk…

CMS has announced another 6-month extension of its current temporary enrollment moratoria for new ground ambulance suppliers and home health agencies (HHAs), subunits, and branch locations in designated metropolitan areas. The moratoria, which affect enrollment in Medicare, Medicaid, and the Children’s Health Insurance Program, apply to:

  • New ground ambulances in the Houston and Philadelphia

…

More than three years after publication of final regulations to implement Affordable Care Act (ACA) provisions that strengthen provider and supplier enrollment screening provisions under federal health care programs, the Centers for Medicare & Medicaid Services (CMS) has selected a Fingerprint-Based Background Check Contractor and intends to phase in fingerprint-based background checks beginning in 2014.
Continue Reading CMS to Implement Fingerprint-Based Background Checks for High-Risk Providers and Suppliers in 2014