March 25, 2020

CMS Allows for Temporary Medicare Provider Enrollment During COVID-19 Emergency

The Centers for Medicare & Medicaid Services (CMS) issued a Frequently Asked Questions (FAQs) on Medicare Provider Enrollment Relief related to COVID-19 on March 23, 2020. CMS is using its authority under Section 1135 of the Social Security Act to provide flexibility with Medicare provider enrollment during the COVID-19 national emergency. This article highlights the changes and waivers CMS will implement during this national emergency.

Physician and Nonphysician Practitioners

For physician and nonphysician practitioners, CMS has established a toll-free hotline to call to receive temporary Medicare billing privileges. Physician and nonphysician practitioners are directed to contact the toll-free hotline associated with the Medicare Administrative Contractor (MAC) that services their geographic area. Fingerprint-based criminal background checks (FCBCs) and site visits will be waived for physician and nonphysician practitioners seeking temporary Medicare billing privileges.

In order to initiate temporary billing privileges, CMS advises that these practitioners have, at a minimum, the following information readily available to provide during the telephone call with the MAC:

  1. Legal name
  2. National Provider Identifier (NPI) number
  3. Social security number
  4. Valid in-state or out-of-state license
  5. Address information and telephone number

During the telephone conversation, the MAC will contemporaneously screen and enroll the physician or nonphysician practitioner and will inform the practitioner of their approval or rejection of temporary Medicare billing privileges. The MAC may assign the practitioner an effective date, retroactive as early as March 1, 2020. Physician and nonphysician practitioners who do not pass the screening requirements with the MAC will not be granted temporary Medicare billing privileges and will not be paid for services furnished to Medicare beneficiaries.

All Other Providers and Suppliers

All other providers and suppliers (including Durable Medical Equipment, Prosthetics, Orthotics and Supplies) are required to submit initial enrollments and changes of information via the appropriate CMS-855 application. CMS will expedite applications received on or after March 1, 2020. Further, all clean web applications received on or after March 18, 2020 will be processed within seven business days, and all clean paper applications received on or after March 18, 2020 will be processed within 14 business days. This is significantly faster than the current standard which is 45 days. CMS strongly encourages providers to submit their application via the internet-based Provider Enrollment, Chain, and Ownership System (PECOS).

CMS will waive the following screening requirements for all enrollment applications received on or after March 1, 2020: (i) application fee (ii) FCBCs and (iii) site visits. CMS also encourages these providers and suppliers to contact their applicable MAC should they have any questions regarding the enrollment process.

Additional Waiver Information

  • The Medicare billing privileges granted pursuant to this wavier are granted on a provisional basis. Once the public health emergency declaration is lifted, all practitioners, providers and suppliers granted temporary privileges will be asked to submit a complete CMS-855 enrollment application to obtain full Medicare billing privileges. The failure to submit the appropriate CMS-855 enrollment application will result in the deactivation of your temporary Medicare billing privileges.
  • CMS advised that there are no payment restrictions on distant site practitioners furnishing Medicare telehealth services from their home. The practitioner, however, is required to update their Medicare enrollment with their home address. If the physician or nonphysician practitioner reassigns their benefits to a group practice, then the group practice is required to update their Medicare enrollment with the practitioner’s home address.
  • CMS is temporarily ceasing revalidation efforts for all Medicare providers or suppliers. CMS will resume revalidation activities once the public health emergency declaration is lifted. CMS is also postponing the Durable Medical Equipment (DME) accreditation and reaccreditation timetables, although DME suppliers should still comply with accreditation requirements. CMS will monitor all billing activity during the national emergency and aberrant billing practices may be subject to further action.
  • Unfortunately, for providers and suppliers that have pending applications received by their MAC prior to March 1, 2020, such applications will be processed in accordance with then existing timeframes. This means web applications will generally be processed within 45 days and paper applications will be processed within 60 days.

As the number of cases around the world grows, Faegre Drinker’s Coronavirus Resource Center is available to help you understand and assess the legal, regulatory and commercial implications of COVID-19.

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