Policy and Your Practice
Simplifying Supplier Enrollment
By Daniel Gurley, AOPA Government Affairs Department
The Centers for Medicare and Medicaid Services (CMS) wants to make
your work easier. It recently changed how it is asking the National
Supplier Clearinghouse (NSC) to deal with missing or confusing data
fields on the CMS 855S application. These changes should simplify the
application process and make it easier for you to deal with the NSC.
Read on to find out exactly how this policy change will affect your
practice.
Why does the change matter?
If you provide Medicare-covered services to Medicare beneficiaries, by
law you must file claims with Medicare for your patients—even if
you do not participate in Medicare or accept assignment.
Medicare orthotic and prosthetic claims are submitted to your Durable
Medical Equipment Medicare Administrative Contractor (DME MAC). The DME
MACs are private companies contracted by Medicare to handle and process
all Medicare DMEPOS claims for reimbursement. In order to submit a
claim to Medicare for payment, you must be enrolled and have a supplier
number.
CMS has contracted with the NSC to enroll all suppliers nationwide. The
NSC distributes applications, verifies data on the enrollment
applications, issues numbers to approved suppliers, and periodically
re-enrolls active suppliers. The NSC also maintains a central data
repository for information on DMEPOS suppliers, and uses the data to
assist with fraud and abuse research.
You know that getting or renewing your supplier number from the NSC is
an important part of your business, and some of you may have
experienced frustrating waits obtaining your number. Perhaps what you
thought was a properly filled-out form came back to you and you had to
resubmit. With this change in policy, things should be different.
Asking for clarification
Until recently, if you submitted a CMS 855S application that had
missing or confusing data, the NSC would immediately reject the
application. CMS is now requesting the NSC prescreen supplier
enrollment applications.
Going forward, the information you submit still needs to be accurate
and complete. But if you submit an application that contains any
missing data fields, the NSC will contact you via e-mail or fax to let
you know information is missing from your application.
Pay careful attention to this notification! It will only happen once.
The NSC will then allow you 60 days from the date they sent the
notification to provide all requested information.
| Do I need to fill out the form? |
| There are several instances where suppliers are required to complete
the CMS 855S application to obtain a supplier number or to re-enroll: • If you are enrolling in Medicare for the first time as a DMEPOS supplier. • If you are a currently enrolled supplier and have been asked to verify or update your information. This includes situations where you have been asked to attest that your organization is still eligible to receive Medicare payments. • If you are a currently enrolled supplier and need to report changes to your business, other than enrolling a new business location (e.g., you are adding, deleting, or changing existing information under this Medicare supplier billing number). These changes must be reported within 30 days of the effective date of the change. • If you are a currently enrolled supplier but need to enroll a new business location. This is to add a new location to an organization with a tax identification number already listed with the NSC. (This differs from changing information on an already existing location.) • If you are voluntarily terminating your Medicare DMEPOS supplier number. |
If additional requests are made based on the supplier’s inquiry
or site visit results, this information must also be submitted during
this 60-day period. If the NSC concludes that the supplier is making a
“good faith effort” to supply the requested information, it
may, at its discretion, continue to process the enrollment
documentation.
If the NSC does not receive the additional data within the 60-day
timeframe, it will reject the application, and you will have to
resubmit it. Suppliers are not able to appeal this decision.
CMS has offered some hints to help you properly fill out the NSC form:
• Review enrollment documentation prior to
submitting it. Ensure all information is accurate and complete, and
include all required documentation.
• Use the helpful hints and checklists available on the NSC Web site. From www.palmettogba.com, under “Providers,” select the NSC link.
• Keep your fax confirmation sheet so that you
can prove the requested information was successfully transmitted.
• Address the response to a specific analyst.
Many responses received are addressed to the NSC and not the analyst
processing the enrollment documentation.
Enrolling (or re-enrolling) in Medicare has never been a simple
process. However, with this change, CMS and the NSC hope to reduce the
amount of paperwork suppliers have to submit. With a better
understanding of the process and the hints given here, enrolling or
re-enrolling in Medicare should be easier.
This article includes information supplied by Brian Banks, Ombudsman at the NSC.
Daniel Gurley is manager of regulatory affairs in AOPA’s
Government Affairs department. Questions? Contact him at (571) 431-0812
or dgurley@AOPAnet.org.
