Medicare Revalidations, Cycle 2

As most of us know, payer revalidations are in full swing. The revalidation process was initiated by CMS to better identify, and close the gap on fraud, waste, and abuse (FWB). The completion of the CMS mandated revalidation process in a timely manner is vital to ensure that Medicare and Medicaid providers are being reimbursed for rendered services.

A trend identified over the course of the revalidation process is that providers do not know there could be a fee associated with their revalidation. The application fee for (CY) 2016 is $554.00 and is assessed to institutional provider/suppliers that submit their applications via PECOS or paper using a CMS-855A, 855B, or 855S forms.

For APS’ client-base, this is for hospitals, independent laboratories, and independent diagnostic testing facilities (IDTF). The fee must be paid prior to the revalidation application being submitted, and proof of payment should accompany the application to revalidate. The fee may be paid by ACH debit, or credit card, and can be paid by visiting https://pecos.cms.hhs.gov/MedicareRevalidation.

Providers/suppliers, including physicians, are required to revalidate their information every five years. Other supplier types, such as those that supply DME, are required to revalidate every three years. The Medicare Contractor (MAC) will notify providers/suppliers at least 60 days prior to their revalidation date.

With the Provider Enrollment Revalidation – Cycle 1, the MAC sent a notice and gave providers/suppliers 60 days to submit revalidation applications. Cycle 2 is different in that CMS is giving providers an actual due date, which is the last day of the month. Generally, this due date will remain with you throughout subsequent revalidation cycles.

With Cycle 1, the email/mailed letter from the MAC requesting revalidation would be sent to the “last known correspondence address.” It was very common during Cycle 1, and is still true for Cycle 2, for providers not to receive the notice. There was not an online method of retrieving the due date until Cycle 2. The new look-up tool is an exciting addition to the revalidation process to hopefully avoid payment interruption moving forward.

Wouldn’t it be easier to submit revalidation applications for all APS clients at one time? 
Absolutely; however CMS says do not submit a revalidation if:

• You have not received an email/mailed letter from your MAC requesting you to revalidate
• Your due date is not listed on https://data.cms.gov/revalidation

The MAC will return any unsolicited revalidation applications.

There haven’t been many changes from Cycle 1; however in summary:

• Due dates will be published by CMS and can be accessed using the look-up tool. APS will query.
• MACs will continue to send notices. When revalidating, we need to revalidate the entire Medicare record including all reassignments and practice locations.
• A development, or request for additional information will be issued on any revalidation received but incomplete. We have 30 days from the date of request to provide the information to the MAC.
• If a revalidation is not received by the due date, the MAC may place a hold on Medicare payments, and deactivate billing privileges.
• If billing privileges are deactivated, a reactivation will result in the same PTAN, but an interruption in billing during the period of deactivation. This will also result in a gap in coverage.
• If the revalidation application is approved, the provider/supplier will be revalidated and no additional action is necessary.