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Ambulatory Coding & Payment Report
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Ramp Up Your Revalidation Process -- Now




Medicare can pull your billing privileges for non-compliance
If you bill Medicare at your facility, you should be getting a strong handle on Medicare’s "revalidation process," if you haven’t already. Why? Because, if you’re not in compliance, it’s only a matter of time until your carrier or fiscal intermediary (FI) can pull the plug on your billing privileges.
Background: According to CMS ruling 42 CFR 424.515 in the April 21, 2006, Federal Register, all Medicare providers must revalidate their Medicare information on file, via a CMS-855 form, within 60 days of receiving a written revalidation request from their CMS fiscal intermediary or carrier, says Lyndean Brick, JD, senior vice president of Murer Consultants Inc. in Joliet, Ill.
That sounds simple enough, but many providers have never filed a complete CMS-855 -- which can make the revalidation process quite difficult, Brick says. You may even receive an on-site survey if CMS discovers enough discrepancies.
But that’s not all: "Generally speaking, once a provider submits a complete CMS-855, either in response to a revalidation request or otherwise, the provider must then revalidate his or her entire CMS-855 filing once every five years -- or within 90 days after any change in his or her Medicare provider information," Brick says.

Know What CMS Wants

If you’re not sure what kind of information you need to have lined up for CMS for revalidation, check out a copy of the Medicare enrollment form online at . You’ll notice that the agency requires a slew of information ranging from your practice name to your licensure status.
You may find that pieces of this required information are out of date for your practice or facility, and if that’s the case, you should fix that fast and submit a fresh 855 form to CMS.
Important: As you update your information, consider consistency a top priority.
"One of the biggest problem areas we find is that providers aren’t consistent with names, among other things in their legal documentation," Brick says.
For example, an ASC may have opened with the name "Physicians Day Surgery," bills as "Physicians Surgical Center," yet its information on file with CMS may say "Physicians Outpatient Surgery Center." CMS won’t go for that.
Critical: And now, with national provider identifier (NPI) requirements going into full-swing, the practice or facility name and other information you’ve filed on your NPI application must match your legal documentation. "Even if one little thing gets out of whack and CMS catches it, its contractors can stop reimbursement," Brick says, "even something as small as your IRS information not matching your NPI information."
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- Published on 2008-05-09
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