CMS Introduces New Provider Enrollment Fees

The February 2, 2011 Federal Register established new regulations related to the provider enrollment process. Per the Federal Register, beginning on March 25, 2011, the Centers for Medicare and Medicaid Services (CMS) will require any institutional provider or supplier to submit a fee up to $505 with the submission of an 855A, 855B and 855S. It appears CMS has excluded physicians and non-physician practitioner organizations from the new regulations. Consequently, a fee may not be required to accompany the submission of an 855I or 855R. CMS has not released an MLN Matters Article as of March 9, 2011, and in recent discussions with representatives from CMS and NHIC, we were not able to confirm if the new enrollment regulations will impact 855I and 855Rs.

The Federal Register is clear with regard to the impact on 855A, 855B and 855S submissions. Any of the aforementioned 855s that are submitted without the newly required fee will be immediately rejected, and CMS could revoke the provider’s Medicare billing privileges. The Federal Register language gives providers the impression the fee will apply to initial enrollment applications, applications to establish a new practice location, and revalidation applications. Our discussions with CMS and NHIC representatives revealed the submission of an 855A, 855B, or 855S for any reason could be subject to the new application fee. We have requested further clarification from CMS and NHIC, and have not received a response to date.

Currently, CMS does not have the means to accept an electronic funds transfer for the fee and is requiring that a check be mailed with the paper based enrollment application, or with the certification statement for the internet based PECOS enrollment application. CMS will not review or approve the 855 until the fee has been deposited into the U.S. Treasury.

The provider enrollment fees also apply to Medicaid and CHIP applications, and are the result of legislation passed as part of the Affordable Care Act. CMS has made a hardship exception request available, however, the exception request must be approved by CMS before the application will be reviewed by a provider enrollment specialist. CMS has informed us that providers should submit any outstanding 855s prior to March 23, 2011 to avoid the new submission fee.

For questions about this or any other provider enrollment topic, please contact Pamela Cook at 1.800.244.7444.

Disclaimer of Liability: This publication is intended to provide general information to our clients and friends. It does not constitute accounting, tax, investment, or legal advice; nor is it intended to convey a thorough treatment of the subject matter.

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