NOTABLE PROVIDER ENROLLMENT INFORMATION
Medicare/Medicaid – Telehealth/Telemedicine Out-of-State Enrollment
More providers are expanding their services into the telehealth/telemedicine arena to provide their patients with better access to care. From an enrollment perspective, Fee-For-Service Medicare requires enrollment of the location where the practitioner is remotely providing services. For example, if the group/clinic brick and mortar facility is located in Georgia (Palmetto GBA) and the practitioner is physically located in Mississippi, then the group/clinic must enroll in Mississippi (Novitas). Additionally, the practitioner must be licensed in the state where they are located. For Fee-For-Service Medicaid, enrollment for both the group/clinic and practitioner is required in the State where the patient received the services. In the example above, the enrollment would be with the State of Georgia (Georgia Department of Community Health). Further, the practitioner must also be licensed in the state where the patient is located.
Medicare Stay of Enrollment
As of May 30, 2024, CMS implemented the Stay of Enrollment (“SOE”) provider enrollment status. In summary, a stay of enrollment can be imposed for non-compliance with at least one Medicare enrollment requirement, however, it can be resolved by the submission of the applicable Medicare application. Examples of Medicare Enrollment Requirements are listed below. Note: This is not an exhaustive list.
- Lack of timely submission of reportable changes; and
- Failure to respond to revalidation requests
The difference between a deactivation and SOE is the provider remains actively enrolled in Medicare during affected period, however claims will still reject with a SOE. A SOE can be enforced for up to 60 days but can be imposed more than once if non-compliance reoccurs. In most cases, the submission of a CMS-855 will result in the removal of the SOE.
CMS-855A Skilled Nursing Facility Attachment
In September 2024, CMS published an updated CMS-855A Application which now includes a Skilled Nursing Facility (“SNF”) Disclosure Attachment, applicable to SNFs only, effective October 1, 2024. This new part of the 855A replaces Section 5 disclosures for SNFs with a much more detailed section to assist with the collection of the SNF data addressed in the CMS guidance. The new SNF attachment must be completed at the time of initial enrollment, revalidation, and/or change of ownership. In short, SNFs must report additional ownership and management information (including private equity companies and real estate investment trusts). As a result of the expanded disclosure, SNFs no longer need to complete CMS-855A Section 5: Ownership Interest and/or Managing Control Information (Organizations), and Section 6: Ownership Interest and/or Managing Control Information (Individuals). CMS also published guidance to assist with the completion of the new attachment portion of the 855A.
Should you have any enrollment questions or needs, please contact Andrea Graham at agraham@advis.com or Valerie Ford at vford@advis.com.
