Don't get thrown out of the Medicare game

Wednesday, May 31, 2006

Q. I have heard that a lot of suppliers are being threatened with termination or are actually being terminated from Medicare because of deficiencies in the re-enrollment process. How can I avoid that result?
A. CMS recently began more strictly scrutinizing new and existing DMEPOS suppliers. Beginning this year, CMS requires the National Supplier Clearinghouse (NSC) to inspect suppliers' licenses and liability insurance annually; provide on-site inspectors, armed with billing histories, to review a minimum number of beneficiary files; inspect off-site inventory storage locations; and conduct out-of-cycle inspections.
Under this enhanced scrutiny, even the most compliant supplier may be cited for violations of one or more of the 21 supplier standards. A supplier should consider the following suggestions in responding to the NSC to reduce the likelihood that its Medicare supplier number will be revoked for a violation:
- Respond to the question asked. For example, if the NSC requests contact information to verify insurance, provide the name and number of the agent or office from which the insurance was obtained. If you do not understand what the inspector/NSC is looking for--ask. Do not provide information or documentation that is not responsive to the request; it may raise additional issues.
- Respond completely. Do not submit a partial response in the belief that "it should be enough."
- Strictly adhere to time deadlines. The failure to timely submit requested documentation may foreclose a supplier's opportunity to informally resolve the matter and may result in the suspension of its supplier number, necessitating a costly hearing and the protracted loss of reimbursement.
- Be sure to report any changes to the information contained in the supplier's application within 30 days of the change; do not wait for an inspection. A late disclosure in response to NSC's request is still a late disclosure--and a violation.


Lester Perling is a partner with Broad and Cassel in Fort Lauderdale, Fla. Reach him at (954) 745-5261 or