The CMS has initiated a new provider enrollment fee for selected Medicare suppliers. The fee applies to institutional accounts enrolling for the first time, those re-validating an existing position or ones adding a new practice location. Starting on March 25^th 2011, Medicare Administrative Contractors will begin collecting the fees along with a provider’s application. The fee has been set at $505 for the fiscal year 2011. Increases in future years will be based upon inflation, as measured by the Consumer Price Index for Urban areas. These fee adjustments will be effective from January 1^st through December 31^st. The amount of the fee owed will be based upon the date of the application.

This new fee will apply only to institutional providers of medical or other times, services or suppliers submitting their application using forms CMS-855A or CMS-855B. The fee does not apply to physicians, physician organizations or non-physician providers and their organizations. According the CMS, those providers subject to the fee assessment can pay it through www.pay.gov immediately after submitting the CMS-855 application or by paper check submitted along with the application or immediately thereafter. The Medicare Administrative Contractions reviewing the application will not be allowed to proceed without the fee having been paid or an exemption having been granted. The fee is nonrefundable except in the case where a hardship exception has been approved, the application is rejected prior to the beginning of the screening process or the application was denied as a result of the the imposition of a temporary moratorium by the CMS.

Hardship Exemption

To qualify for a hardship exemption the provider must make a strong argument and provide all necessary supporting documentation. For an exemption based upon low profit/capital position, the provider must submit historical costs, recent financial reports or tax returns to substantiate it’s claim. Other positions that may suggest that a hardship exception is warranted include: Heavy bad debt expense, a significant level of financial assistance furnished to patients, being a significant member/partner of an organization that furnishes a disproportionate amount of medical care to low income populations, Whether an institutional provider receives considerable amounts of funding through disproportionate shared hospital payments, whether the provider is enrolling in a declared disaster area.

The CMS has 60 days to approve/disapprove a hardship exemption. If the request was turned down and the provider has not yet submitted the fee it has 30 days to do so. If the provider wishes to appeal the CMS decision, it may file a written request to reconsider with the CMS within 60 days of receipt of the initial decision notification.

The CMS considers the $505 fee to be well within the abilities of any well funded institutional provider enrolling in Medicare. The burden of proof is likely to be high and it will be the provider responsibility to make make it’s case, employing strong logic along with substantial supporting evidence. At the end of the day, unless it’s are real hardship for your organization, the best course of action is to go ahead and pay the fee thereby likely saving yourself an extra 60 days in the provider enrollment process. To learn complete details check here.

As of March 25, 2011 the new CMS provider enrollment rules are enacted.  We covered most of the proposed changes in a previous blog post so we’ll just briefly touch on them here.  The primary objective of these changes is to address and help minimize the incidents of  fraud and abuse in the Medicare program.  The new processes includes additional screening,  the suspension of payments where allegations of fraud exist and the new rules grant the CMS the authority to impose a temporary moratorium on new enrollments for particular types of practices in particular geographic areas. There are also new application fees and procedures included as part of the rules revamp.

The new screening process includes assigning providers and suppliers to one of three risk levels: limited, moderate or high.  The screening process will be more detailed and involved the higher the assigned risk category.

Non-refundable Application fees will be charged when initially enrolling in Medicare, when adding a practice location or when revalidating enrollment information.  The fee for March 25, 2011 until Dec 31, 2100 is $505. There are hardship exceptions and refunds are possible if an application is rejected during screening or a temporary moratorium has been applied.

CMS is given the right to impose a moratorium on the enrollment of new Medicare providers of a particular type in a particular geographic areas and the establishment of new practice locations of those types in said locations.  This moratorium would be in response to a high incident of fraud and abuse allegations.

As a practical matter these procedurally changes are likely to have little effect on the typical provider enrollment process.  Where they do come into play it will make the enrollment process considerably more complicated and involved.

The detailed instructions can be found here