All providers and suppliers who enrolled in the Medicare program prior to March 25, 2011, will be required to revalidate their enrollment by March 25, 2012 under new risk screening criteria required by the Affordable Care Act (section 6401a).
Newly-enrolling and revalidating providers and suppliers are placed in one of three screening categories representing the level of risk to the Medicare program. The three categories, limited, moderate, or high, determine the degree of screening to be performed by the Medicare Administrative Contractor (MAC) processing the enrollment application.
Palmetto GBA will begin notifying physicians and entities to revalidate in September. Their plan is to start with those physicians and other organizations who are enrolled in Medicare, but do not yet have complete profiles in PECOS (Provider Enrollment, Chain, and Ownership System). They will also send revalidation letters to all Independent Diagnostic Testing Facilities (IDTF). The remainder of the physicians and providers will receive letters over the next 19 months, in an order still to be determined. Upon receipt of the revalidation letter, physicians and organizations will have 60 days to respond.
Here are a few items to remember during the initial start-up of this effort:
- Yes, this applies to any individual or organization that enrolled or revalidated prior to March 25, 2011.
- Do not do anything until you get a letter instructing you to revalidate. (This is very important in order to ensure an orderly enrollment process.)
- CMS is working on simplifying this process on the Internet-based PECOS system, hopefully for January 2012.
- Palmetto is working with CMS to establish a schedule that will accomplish the regulatory requirement and avoid any disruption in payment to physicians.
- Physicians who are making changes (moving, closing practice, etc.) should continue to submit their changes as usual.
CMS has published a Special Edition Article #SE1126 to further explain this revalidation requirement.