October Legislative Update: Medicaid/Medicare Re-enrollment
Update on Federal Issues
Federal changes with the Affordable Care Act (ACA) require re-enrollment of all Medicaid providers (pharmacies, hospitals, DME providers, etc.). For pharmacies, the deadline for this re-enrollment is December 31, 2012. Medicare providers will also need to re-enroll with Medicare.
An application fee is associated with the re-enrollment process. For those applications submitted in 2011, an enrollment fee of $505 applies to each application. Unfortunately, pharmacy and DME are counted as separate applications. However, for those who are applying as both Medicare and Medicaid providers, only one application fee per license is required (i.e., you will not pay an application fee to both Medicare and Medicaid). In these instances, Medicaid requires proof of either a completed Medicare application or payment of an application fee to Medicare. Application fees will increase in 2012, although likely only marginally.
For example: Pharmacy X has both a Pharmacy and DME license. They pay a $505 application fee to Medicare for their Pharmacy application, and another $505 fee to Medicare for their DME application. When applying for Medicaid re-enrollment, proof of payments made to Medicare is submitted to Medicaid, which then does not require any further application fees. So Pharmacy X paid a total of $1010 to re-enroll both their Pharmacy and DME licenses with both Medicare and Medicaid.
An enrollment application with the application fee payment can be submitted in one of two ways.
1. The easiest and quickest way to revalidate your enrollment information is by using Internet-based PECOS (Provider Enrollment, Chain, and Ownership System), at https://pecos.CMS.hhs.gov. Once you have completed and submitted your enrollment application using Internet-based PECOS, you should then promptly pay the application fee through www.Pay.gov. Once you are on Pay.gov, type ‘CMS’ in the search box under “Find Public Forms” and click the “GO” button. Click on the “CMS Medicare Application Fee” link. Complete the form and submit payment as directed. You will get a confirmation screen indicating that payment was successfully made. This confirmation screen is your receipt and should be printed for your records. CMS recommends that this receipt be mailed to the DME MAC along with the Certification Statement for the enrollment application. CMS will notify the DME MAC that the application fee has been paid.
2. Complete the paper Medicare enrollment application (CMS-855). Once you have completed filling out the CMS-855 paper application, you should promptly pay the application fee through www.Pay.gov. Once you are on Pay.gov, type ‘CMS’ in the search box under “Find Public Forms” and click the “GO” button. Click on the “CMS Medicare Application Fee” link. Complete the form and submit payment as directed. You will get a confirmation screen indicating your payment was successful. This confirmation screen is your receipt and should be printed for your records. CMS recommends that this receipt be mailed to the DME MAC along with the completed CMS-855 application. CMS also notifies the DME MAC that your application fee has been paid.
You must use pay.gov to pay your application fee. Do not mail application fee payments. Users may not make multiple payments in one transaction and must make separate payments for each application. If you have problems submitting your application fee, you should use the Help Tools available on the Pay.gov site for questions specific to the payment processing. Other questions regarding payment policies and procedures may be sent to the Medicare provider and supplier enrollment email account at Dpse_admin@cms.hhs.gov.
For more information about provider revalidation, review the Medicare Learning Network’s Special Edition Article #SE1126, titled “Further Details on the Revalidation of Provider Enrollment Information.”
Surety Bond Information
If a pharmacy is NOT going to become a DMEPOS- accredited provider, but still wants to bill for Part B drugs, they still have to purchase a surety bond.
The pharmacy must submit revisions to Section 2.C of the 855S to ensure their billing number remains intact for billing the Part B drugs. Sections 1, 2, and 15 or 16 must be reviewed/revised as appropriate and sent to the NSC. Also, Surety bond information must be submitted, including sections 2.G and a copy of the bond sent to the NSC. CMS 855S form can be found at: (https://www.cms.gov/cmsforms/downloads/cms855s.pdf).
The U.S. Department of Treasury’s Listing of Certified (Surety Bond) Companies can be found at www.fms.treas.gov/c570/c570_a-z.html.
If a pharmacy voluntarily terminated its DMEPOS enrollment and acquires a surety bond in the future, an updated CMS-855S form will need to be submitted to re-enroll in the program.
If you have any questions or comments about the issues mentioned in this article, please contact Kelly Vyzral, Director of Government Affairs, at 614.389.3236 or firstname.lastname@example.org.