A Detail at the Deadline

It’s here. The Sept. 30, 2009, accreditation deadline is here, and whether or not you’ve become accredited, you may have some critical paperwork to do.

If you are accredited, you may need to communicate this information to the National Supplier Clearinghouse via the CMS 855S enrollment form right away. Your accreditor reports your status to Medicare, but you must report this as well. Once you update your information at the NSC, the report from the accreditor is “matched” to the status report you have made through your 855S form.

I was amazed to learn at a recent conference that many providers who have become accredited this year were unaware they needed to inform the NSC of their accreditation status. They were under the impression that the accreditor reported this information.

That is true, and some CMS officials have said that if accrediting organizations report a provider’s status to the NSC, then that will be sufficient. However, this could be just another example of the right arm not knowing what the left arm is doing at Medicare. Making sure your information is on file is a critical detail you need to be aware of for the survival of your business.

The NSC is the body Medicare contracts to maintain enrollment for all Part B DMEPOS providers. The way providers communicate with the NSC, and thus Medicare, is via the 855S form. It’s a 39-page form with pages of directions that stipulate required attachments be sent with certain updates to ensure that the form is processed correctly and in a timely manner. (You can find the form at www.cms.hhs.gov/cmsforms/downloads/cms855s.pdf.)

Even though you might have reported your accreditation to the NSC in the past — and even though the last few revisions to the 855S have included a box to list accreditation status — the NSC has only begun to update this information in providers’ files.

That means even providers who have been accredited for years and were re-accredited recently may not have their accreditation status on file. If you have been accredited or even re-accredited anytime in the past three years, you must update your accreditation information via an 855S form immediately. If you do not report your accreditation status to the NSC prior to the Sept. 30 deadline, your accreditation will not be on file and you risk having your provider number terminated on Oct. 1 with your billing privileges revoked.

If you began the accreditation process after Jan. 30, 2009 (CMS’ suggested soft deadline), and you are not presently accredited or waiting for your unannounced survey — or if you plan to start the process soon and become accredited within the next year — you must update your provider status via your 855S form or risk losing your billing privileges for one year.

If Medicare revokes your supplier number on Oct. 1, there is a mandatory one-year waiting period before you can re-apply. If you voluntarily suspend your number, however, you can re-apply once you are accredited without having to wait the mandatory one-year period.

Pharmacies that have chosen not to become accredited need to change their Part B status to Part B drugs only or risk having their billing privileges suspended for one year as well.

Additionally, as of press time, there have been no changes to the upcoming requirement for surety bonds. Providers under Part B, whether for drugs only or for DMEPOS items, must have a surety bond on file by Oct. 2, 2009. Right now there are no exceptions. Providers must also submit their bonding information to Medicare through the NSC via the 855S form.

If you have any information to update with Medicare, download the 855S form right away. Read the instructions carefully to make sure you complete all of the required areas and include all required attachments. Keep a copy of everything you send, and send the completed documents and any applicable attachments to the NSC by some method of return receipt to ensure your documentation is received prior to Sept. 30.

Don’t miss this important deadline or rely on someone else to make sure your billing privileges remain active.

Read more Accreditation Now columns.

Mary Ellen Conway, RN, BSN, is president of Capital Healthcare Group, LLC, Bethesda, Md., which provides health care management expertise in accreditation preparation and survey follow-up, operations assistance, design of quality improvement programs and outcome measures. She can be contacted by phone at 301/896-0193 or through www.capitalhealthcaregroup.com.