Medicare Provider Enrollment: Strategies for Denials, Revocations and Appeals

Challenging Adverse Enrollment Determinations and Ensuring Billing Privileges Amid Expanded CMS Authority

Recording of a 90-minute CLE webinar with Q&A

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Conducted on Thursday, January 7, 2016

Recorded event now available

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Course Materials

This CLE course will provide guidance to healthcare counsel on appealing Medicare enrollment denials and revocations. The panel will dicuss the impact of the CMS final rule that expanded its authority to revoke billing privileges and what healthcare providers and suppliers should do in light of the final rule.


In December 2014, the Centers for Medicare & Medicaid Services (CMS) issued the final rule on Requirements for Medicare Incentive Reward Program and Provider Enrollment, which went into effect in February. The final rule put in place provider enrollment requirements and expanded the CMS’ authority to revoke Medicare billing privileges. Since the final rule became effective CMS has wielded its authority to revoke privileges from more providers.

Medicare provider enrollment is a significant driver in the delivery of services and payment. When enrollment is granted is critical and, consequently, often contested. Denial or revocation of Medicare provider enrollment can result in uncompensated services.

Providers should judiciously appeal claim denials to avoid the perception of a pattern of abuse under the final rule, which could trigger revocation. The final rule provision is a strong enforcement tool for CMS and one that providers and suppliers should factor in when billing Medicare.

Listen as our authoritative panel of healthcare attorneys reviews the new rule and examines how the CMS is using the provision against providers and suppliers. The panel will provide guidance on appealing determinations—requests for reconsideration, CAPs, agency and court appeals.



  1. New CMS rule—expanded authority
  2. How CMS is using the provision against providers and suppliers
  3. Strategies for appealing determinations
    1. Requests for reconsideration
    2. Corrective action plans
    3. Agency appeals
    4. Court appeals


The panel will review these and other key issues:

  • How has the final rule impacted how CMS is approaching and treating enrollment applications?
  • What approaches are most effective for responding to a notice of enrollment deactivation, revocation of billing privileges or termination?
  • How can providers appeal an enrollment revocation of billing privileges or termination decision?


Gustafson, Jessica
Jessica L. Gustafson

Founding Shareholder
The Health Law Partners

Ms. Gustafson practices in all areas of health care law and devotes a substantial portion of her practice to...  |  Read More

Andrew B. Wachler
Andrew B. Wachler

Managing Partner
Wachler & Associates

Mr. Wachler has been practicing health care law for over 30 years. He counsels healthcare providers and organizations...  |  Read More

Donald H. Romano
Donald H. Romano

Special Counsel
Foley & Lardner

Mr. Romano has extensive experience counseling hospitals, skilled nursing facilities and academic medical centers and...  |  Read More

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