Board Member Disclosures: 4 Must-Do’s to Ensure Enrollment Compliance
The Federal government sees the accurate, complete and timely reporting of ownership interests as a key strategy for limiting fraud in the Medicare and Medicaid programs. If new members joined your Board of Directors in 2018, it’s important to update your information with CMS to ensure your Medicare/Medicaid enrollments remain compliant.
Here are four “must-do’s” to avoid costly penalties, lost billing and even deactivation of your billing number:
1) Obtain key information from new Board members. CMS requires full legal name, Social Security Number, date of birth, and the state/province and country of birth. There is a 90-day timeframe to report new board members to, and to remove old board members from, Medicare/Medicaid enrollments. A good idea is to request a copy of the board member’s driver’s license as certain states require a copy upon application submission.
2) Keep a record of start and end dates of current/past board members. This is the information that is hardest to obtain when cleaning up Medicare/Medicaid enrollment records. A start date is needed to add a Board member and an effective end date is required to remove a board member.
3) Have Board members complete a questionnaire once a year that includes disclosure of felony activity and/or licensure/certification revocations. Medicare, and in many states, Medicaid, require this information; supporting documentation should be put on file as well. Certain state Medicaid agencies may also require that minor convictions and arrests of a non-traffic nature be disclosed as well. Failure to disclose this information can result in the rejection of a pending application or even deactivation of a Medicare/Medicaid billing number.
4) Update Medicare/Medicaid enrollments within 30 days of a signatory (Authorized/Delegated Official) change. It is important to make sure the person appointed to sign off on all Medicare/Medicaid filings is kept up to date. Particularly true on the professional billing side, the signatory is required to sign off on practitioner reassignments. If the Authorized/Delegated Official is not updated in a timely fashion, billing could be lost as practitioners need to be added.
Advis is experienced and efficient in Board of Directors’ Medicare/Medicaid updates. If you’ve recently had a Board change that needs reporting, we can help. Give us a call at 708-478-7030 or fill out the electronic form.