CMS Final Rule Revising Provider and Supplier Enrollment Requirements: Expansive CMS Denial and Revocation Authority

Description

The CMS recently finalized significant updates to Medicare's provider and supplier enrollment regulations at 42 C.F.R. 424, Subpart P, and related changes to Form CMS-855A as part of CMS' efforts to increase oversight of the Medicare program and to enhance program integrity and transparency. These changes affect new and existing Medicare providers and suppliers and create new and ongoing compliance obligations of which counsel should be aware given CMS' broad authority and the potentially harsh consequences for noncompliance.

Notable updates to the enrollment requirements include increasing the scope of CMS' authority to revoke or deny enrollment in the Medicare program; reducing the timeframe for reversing a revocation; and expanding the reapplication bar to 10 years for severe provider or supplier misconduct. The regulations also create a new "stay of enrollment" status, an interim status that may be imposed prior to any deactivation or revocation action, that allows for the provider or supplier to remain enrolled in Medicare.

Other changes include new and clarified definitions of certain provider enrollment concepts such as "indirect ownership interest" and "supplier," and new enrollment categories for marriage and family therapists and mental health counselors.

In addition to the changes in enrollment requirements, CMS has updated Form CMS-855A for the first time in 12 years with substantive and administrative updates.

Listen as our expert panel guides practitioners through the new CMS enrollment requirements for providers and suppliers. The panel will address notable updates in the enrollment regulations and changes to Form CMS-855A. The panel will also discuss consequences of noncompliance and provide best practices to mitigate risk.