APMA News - July/August 2012 - (Page S1)

your By Donna J. Senft, PT, JD, Principal, Ober|Kaler APMA SUPPLEMENT TO APMA NEWS Trusted News and Information for Young Physicians JULY / AUGUST 2012 / ISSUE 5 MEDICARE ENROLLMENT: BOOT CAMP BASICS, PART II K WHY KEEP ENROLLMENT DATA CURRENT? eeping enrollment data accurate and complete should be a focus of any compliance program for a Medicareenrolled provider or supplier. Beginning in June 2006, CMS implemented regulations that provide sanctions for failing to maintain current data and provide timely notification of enrollment data changes. These 2006 changes authorize CMS or its contractors to deactivate (under 42 C.F.R. § 424.540(a)(2)) or to revoke (under 42 C.F.R. § 424.535(a) (9)) billing privileges simply for not having current enrollment data on file. Deactivation is the temporary suspension of billing privileges and does not result in a termination of the participation agreement. However, in order to reactivate billing privileges, the enrollee may need to complete a new CMS 855I or CMS 855B enrollment application form. Because the effective date for the reactivation of the enrollment for a podiatrist or podiatry group would be based on the application receipt date, there might be a gap in the enrollment effective dates and subsequent lost revenue if services were provided to Medicare beneficiaries during the gap period. A billing privilege revocation results in an automatic termination of the participation agreement. With regard to the revocation effective date, as a general rule the revocation becomes effective 30 days following the date of the written revocation notice. However, for revocation actions based on final adverse actions, the revocation is typically retroactive because the effective date of the adverse action becomes the revocation effective date. Effective August 26, 2008, new regulations at 42 C.F.R. § 424.535(c) added a mandatory one- to three-year bar to Medicare re-enrollment following a billing privilege revocation. Another set of new regulations became effective January 1, 2009, shortening the time period to report certain changes (42 C.F.R. § 424.516(d), discussed below) and authorizing CMS to initiate certain overpayment actions for services provided from the date of the reportable event (42 C.F.R. § 424.565). Lastly, as required by the Affordable Care Act, effective March 23, 2011, CMS implemented regulations at 42 C.F.R. § 455.416(c) that require Medicaid enrollments to be terminated when a Medicare billing privilege revocation occurs. The Medicaid termination does not become effective until the exhaustion of any Medicare appeal right. Similarly, many third-party payers require reporting of Medicare billing privilege revocations and will terminate the payer contract as a result of such action. WHAT ARE THE TIME FRAMES FOR REPORTING CHANGES? The enrollment rules set different time frames for reporting changes for different types of providers and suppliers. For physicians and non-physician practitioners, individuals, and groups, the regulations at 42 C.F.R. § 424.516(d) require Medicare enrollment data changes to be reported according to the following time frames: 30-day Reporting: Any Change in Ownership or Control: This definition includes not only a complete change in ownership, such as the sale of a practice, but also partial ownership changes and changes in control. Reportable ownership interests of group practices include: for partnerships, any partner irrespective of the percentage ownership; and, for other types of entities (e.g., corporations, limited liability companies), any individual or entity that holds a 5-percent or more Continued on Page 2 APMA IS SOCIAL: ARE YOU? TWITTER. Catch up in 140 characters or fewer. @APMATweets FACEBOOK. Be our friend. www.facebook.com/TheAPMA APMA gratefully acknowledges the support of Upsher-Smith, sponsor of Your APMA, and PICA, founding sponsor of the Young Physicians’ Program. YOUTUBE. Watch what we do next. www.youtube.com/user/TheAPMA http://www.facebook.com/TheAPMA http://www.youtube.com/user/TheAPMA

Table of Contents for the Digital Edition of APMA News - July/August 2012

APMA News - July/August 2012
President’s Message
Contents
Innovative, Intuitive, Inventive
Health Policy & Practice Committees Meet to Address Issues Facing Podiatrists
MPMA Instrumental in Uncovering Health-care Fraud
Does the Media Still Matter?
Introducing APMA’s ACO Workgroup
APMA By the Decade
The US House of Representatives Recognizes APMA’s 100th Anniversary
2011 Podiatric Practice Survey
Profiles in Progress
Reimbursement
Federal Advocacy Forum
List of Cosponsors to the Equity and Access for Podiatric Physicians Under Medicaid Act
APMAPAC Chair Report
IT Consultant
Technofile
Get 2012 Annual Scientific Meeting Coverage
Annual Scientific Meeting Preliminary Program
Annual Scientific Meeting Sponsors
Annual Scientific Meeting Registration Form
APMA All Stars
In Short
CPME Invitation for Comments
Worthy of Note
Call for Committee Nominations
Affiliates Corner
List of Affiliated Organizations
Insurance Advisor
Bylaws Propositions Due
New Members
Death Notices
APMAPAC Update
Development Update
Classified Advertising
Dates to Remember
Advertising Index
10 Questions
Your APMA
100th Anniversary Commemorative Section

APMA News - July/August 2012