The Affordable Care Act establishes a requirement for all enrolled providers and suppliers to revalidate their enrollment information under new enrollment screening criteria. This revalidation effort applies to those providers and suppliers that were enrolled prior to March 25, 2011. Newly enrolled providers and suppliers that submitted their enrollment applications to CMS on or after March 25, 2011, are not impacted. This requirement applies to all providers and suppliers who enrolled in Medicare prior to March 25, 2011, via 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). These contractors are collectively referred to as MACs). MACs are sending out notices on a regular basis through March 23, 2013 to begin the revalidation process for each provider and supplier. Providers and suppliers must wait and submit the revalidation only after being asked by their MAC to do so.

Newly-enrolling and existing Medicare providers and suppliers, beginning on March 25, 2011, have been placed into one of three levels of categorical screening: limited, moderate, or high. The risk levels denote the level of the contractor’s screening of the provider when it initially enrolls in Medicare, adds a new practice location, or revalidates its enrollment information. Skilled nursing facilities have been placed in the lowest category, that of limited risk.

In February of 2011, American Health Care Association (AHCA) staff surveyed its membership regarding problems associated with the 855 forms and process. A detailed letter was sent to CMS at the end of February, which included suggestions for improvement:

"We wish to bring to your attention serious problems with the Medicare 855A enrollment process and the Center for Medicare & Medicaid Services’ (CMS’s) Provider Enrollment, Chain, and Ownership System (PECOS), the national database of enrollment information submitted to CMS by Medicare providers through Form 855. We ask that CMS proceed to correct these problems, and AHCA stands ready to help in any way possible."

Upon receipt of the recommendations, CMS asked to meet with AHCA — and progress was made in many areas. On October 28, 2011, AHCA staff had a conference call with the CMS enrollment team. The CMS team believes that it is making process regarding both PECOS issues and the 855 process itself. The CMS staff has asked us to meet with AHCA in January for a review of all of our recommendations and CMS work since they submitted the recommendations earlier this year. In the interim, if providers run up against intractable 855 problems, we need to gather that information in advance of their January meeting, so please forward your issues to Todd Bergstrom at the Association office: tbergstrom@careproviders.org.

Patti Cullen, CAE
952.851.2487
pcullen@careproviders.org

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