AMARILLO, TX – Staying on top of your Medicare enrollment is more important than ever because your Medicare provider transaction access number or PTAN is the key to billing Medicare beneficiaries. There have been a lot of changes related to supplier enrollment in the last few years. First, suppliers went from working with one enrollment contractor to working with two.
Further, the transition from the National Supplier Clearinghouse to the National Provider Enrollment East and West was not a smooth transition. When Novitas took over processing enrollments for the eastern portion of the United States, there was a large backlog of applications which took quite a bit of time to be worked. Overall, in both the NPE East and NPE West, we have seen processing times for all types of applications increase.
We have also seen more deactivations and revocations. Many of the deactivations were for issues that could have easily been cured. In the case of a deactivation the increased processing times have left suppliers unable to bill for longer periods of time, forcing the suppliers to hold claims. In addition, suppliers have experienced gaps in the ability to bill. A reactivation is effective the date it is received by the NPE. If a supplier’s PTAN is deactivated, it should as soon as possible submit am 855S requesting reactivation to avoid or limit any gap in billing.
In the case of a revocation that requires the filing of a corrective action plan or an appeal, this process has also experienced significant delays. This appeal contract was awarded to Chags Health Information Technology, LLC or C-Hit on October 9, 2023. Unfortunately, this was not a smooth transition and suppliers have again experienced significant delays with responses often taking longer than the time frames allowed by CMS. CMS is working with C-Hit to solve the delays but in the meantime, these delays can create trouble for a supplier having to appeal a PTAN revocation
To avoid enrollment issues, suppliers are encouraged to review the info on file with CMS and make necessary updates. Changes to the information on file with CMS should be reported within 30 days of the change. One particular area that should be reviewed is the electronic funds transfer (“EFT”) form. On April 25, 2024, Medicare sent letters to those not receiving Medicare payments via EFT.
In accordance with 42 CFR 424.510(e)(1), and Pub 100-08, Chapter 10, Section 10.6.10 of the Internet-Only Manuals, all providers and suppliers are required to receive payments via EFT. This means that all suppliers should ensure they have downloaded and completed the current version of the paper EFT form. If an EFT form is not submitted by the due date of July 24, 2024, a supplier will have its Medicare billing privileges deactivated.
To reactivate, the supplier will need to complete a full 855S and wait for it to be processed. This process can take 90 days or longer which means the supplier will be unable to submit claims during this time. Suppliers may also end up with a gap in their ability to bill.
At this time more than any other, it is important for suppliers to be proactive in monitoring their compliance with the supplier standards and ensuring that any changes to the information on file with CMS are updated promptly. Being proactive will save the supplier from being subjected to deactivation, or even worse, a revocation.
Denise M. Leard, JD, is an attorney with the Health Care Group of Brown & Fortunato, a law firm with a national health care practice based in Texas. Leard represents HME companies, pharmacies, and other health care providers throughout the United States. She can be reached at (806)345-6318 or [email protected].
