September 9, 2011

According to a recent special edition article in the Center for Medicare & Medicaid Services’ (CMS) online MLN Matters, a publication for Medicare professionals, physicians who enrolled in Medicare before March 25, 2011 and provide health care for Medicare patients will be required to revalidate their Medicare enrollment upon receiving notification from their individual administrative contractors.

The revalidation requirement is derived from Section 6401(a) of the Patient Protection and Affordable Care Act, “Medicare, Medicaid, and Children’s Health Insurance Programs; Additional Screening Requirements, Application Fees, Temporary Enrollment Moratoria, Payment Suspensions and Compliance Plans for Providers and Suppliers” Federal Register 76:22 (February 2, 2011) p. 5862.   To combat fraud, Section 6401(a) mandates certain screening procedures for physicians and other health care providers of Medicare and Medicaid beneficiaries as well as those who participate in the Children’s Health Insurance Program.   As part of the screening program, enrollment in Medicare and/or Medicaid of all registered providers must be revalidated under new enrollment screening criteria.

The revalidations will be processed by Medicare contractors in the same manner as initial credentialing applications of Medicare/Medicaid.  Contractors will be provided with a list of physicians and health care professionals who have had a previous adverse action, such as license revocation, felony conviction or exclusion from federal health care programs.  New enrollments and revalidations will be checked against this list and physicians on the list could potentially be subject to higher levels of scrutiny.

It is important to note that the revalidation notification will continue through March 23, 2013.  No action need be taken until notification is received from Medicare’s Contractors (Fiscal Intermediaries (FIs), Regional Home Health Intermediaries (RHHIs), Medicare Carriers, A/B Medicare Administrative Contractors (A/B MACs), and the National Supplier Clearinghouse (NSC)).  Once the revalidation notification is received, providers are given sixty days to respond to the request.   However, no action will be required if a provider enrolled on or after March 25, 2011 because these providers’ applications were subject to a stricter level of scrutiny.   “Failure to submit the enrollment forms as requested may result in the deactivation of your Medicare billing privileges,” CMS stated.