The Centers for Medicare and Medicaid Services (CMS) has shortened the time frame from 27 months to 30 days under which physicians can bill retroactively for services after successful enrollment or re-enrollment in Medicare. Thirty days also is the time frame for doctors to notify their contractors of reportable events such as a change in practice location, change in ownership, and final adverse action (i.e., suspension or revocation of license).
The new timeline comes as a result of the 2009 Medicare physician fee schedule final rule which implemented several changes to the enrollment policy. The AOA, along with the AMA and other physician associations opposed the changes, noting that the changes would do more to aggravate enrollment challenges that already exist. Physicians have long complained that the enrollment process already is too cumbersome, time-consuming, and administratively burdensome.
The effective date for billing privileges for physicians is the later of the date of filing of a Medicare enrollment application that was subsequently approved by a Medicare contractor or the date an enrolled physician first began furnishing services at a new practice location.
Apply for Enrollment
Physicians and non-physician practitioners can apply for enrollment in the Medicare program or make a change in their enrollment information using either of the paper-enrollment application process (CMS-855I or CMS-855R) or the Internet-based Provider Enrollment, Chain and Ownership System (PECOS). The agency hopes that PECOS will help streamline the process and alleviate burdens related to the paper-based process.
Several changes to the enrollment process are in effect. For example:
A physician must submit a signed certification statement and supporting documentation with seven days of the electronic submission.
For applications submitted through PECOS, Medicare contractors must process 90 percent of the applications within 45 days of receiving the signed and dated certification statement and supporting documentation.
CMS requires Medicare contractors to process 80 percent of initial paper enrollment applications within 60 days, and 80 percent of paper changes and reassignments within 45 days.
A physician can file an enrollment application up to 30 days before providing services at the designated location.
A physician has up to 90 days to notify the Medicare contractor of all other changes in enrollment information other than the information subject to the 30-day notification window.
If errors are found on the application, physicians have 30 days to request a corrective action from the Medicare contractor in order to preserve the initial filing date and original retroactive billing window. CMS reserves the right to perform an onsite review of a provider or supplier to verify that the enrollment information submitted to CMS or its agents is accurate and to determine compliance with Medicare enrollment requirements.
Based on the results of the review, CMS may deny or revoke a physician’s Medicare billing privileges if he/she is unable to furnish Medicare-covered services; has failed to satisfy any of the Medicare enrollment requirements; or failed to furnish Medicare covered items or services as required by the statute or regulation.
CMS also can revoke enrollment and billing privileges in the Medicare program if the physician did not comply with reporting and documentation requirements in the enrollment process. The physician must submit all claims for items and services furnished within 60 calendar days of the effective date of revocation. (These requirements apply to other providers and suppliers as well.)