Revalidation: Cycle 2 has Sharper Teeth

Recently on a CMS conference call, the parameters of the Cycle 2 Revalidation were made known to providers who attended the telephone conference call. Revalidation is required for all providers enrolled in Medicare. DMEPOS providers revalidate every 3 years.  All other providers revalidate every 5 years.

CMS is compiling a table of revalidation filing due dates. CMS has a data look up for revalidation, and a sample PECOS revalidation form for your review on its website. Go to cms.gov and input “validation list” in the search box. The first result (currently Revalidations - Centers for Medicare & Medicaid Services) will take you to an article that gives you links to both the due date list and the PECOS revalidation sample form.

Things to know: 

Cycle 2 Late Filing Revalidations.   If you late file your revalidation in Cycle 2, your enrollment will be deactivated.  Whereas in Cycle 1, your payments were merely suspended until you filed the revalidation forms, in this instance, your enrollment is deactivated.  Once you file your revalidation form late, you will get to keep your NPI number, but your enrollment will be brand new.  CMS and the contractors will not reactivate your prior enrollment, but will re-enroll you or your entity.  You will not get to bill for any services provided during the deactivation period. 

Notice Letters. Each provider is scheduled to receive a notice letter for the revalidation.  If you do not receive a letter for some reason, you need to timely file your revalidation anyway.  Therefore, CMS recommended you check the Due Date List every month.   If your entity currently has TBD (to be determined) as the due date, your revalidation is not yet due, but keep checking.  The list is intended to give you approximately 6 months lead time.  

Group Enrollments that also have Individual Enrollments. Your groups and individuals may not have the same revalidation due dates.  Therefore, you must be diligent about keeping the Due Date List checked regularly.

855O enrollees. Those practitioners who has enrolled for ordering Medicare services only may be treated slightly differently, so please check the Due Date List, and call your enrollment contractor to make certain you understand the procedure you must go through for this process.

Change of Address, Ownership, Management, Adverse Legal Actions, etc. If you change addresses, ownership, managers, adverse legal action changes, or any other change that would necessitate filing an 855 form with your CMS contractor - go ahead and timely file the reported change on the appropriate 855 form as you normally would.  The Revalidation is not to take the place of reporting changes.