Page 8
The new health reform law includes several provisions that affect both Medicare and Medicaid enrollment.
Practice Management
New Health Reform Law Brings Medicare Enrollment Changes
The law also dictates that these new measures be included as part of provider enrollment in state Medicaid programs. In addition to the requirements detailed above, state Medicaid programs also must require that ordering and referring physicians be enrolled in their program and that the National Provider Identifier (NPI) of ordering or referring physicians be included on claims. This is a new requirement for the Medicaid program, and states will need to revise their provider agreement processes to collect this information. CMS in May released an interim final rule on Medicare and Medicaid provider enrollment that addresses these NPI requirements. Under the rule, all practitioners enrolling in the Medicare or Medicaid programs as of July 6 must include their NPI in their application materials. NPIs also must be included on all Medicare and Medicaid claims, along with the ordering or referring practitioner’s legal name. The ACC recommends that members ensure their Medicare provider enrollment information is current and accurate. If it is not, enrollment applications should be submitted as soon as possible, but certainly by July 6 (see related article on new ordering and referring policies). Practitioners who enrolled in Medicare prior to 2003 and have not updated enrollment records since that time are likely not to have an enrollment record in the Medicare provider enrollment database. To ensure that one is created, a Medicare provider enrollment application (CMS-855 form) must be completed. Medicare contractors are reported to be experiencing higher than normal volumes of Medicare provider enrollment application submissions as a result of the new changes. Please contact the ACC if you experience sustained delays of six months or more. For more information, visit the “Practice Management” section of CardioSource.org and click on “Coding and Billing.”
The ACC will keep you informed regarding any late-breaking developments in this area. However, given the fast-approaching deadline, the ACC strongly recommends that practices prepare a written identity theft detection and prevention program. The AMA and Medical Group Management Association have developed Red Flags Rule guidance documents and sample policies that can be modified, which can be accessed at the MGMA Red Flags Rule Resource Center (www.mgma.com/policy/default. aspx?id=22932), and the AMA Red Flags Rule Physician Resources (www.ama-assn.org/ama/no-index/ physician-resources/red-flags-rule.shtml ). The Federal Trade Commission’s (FTC) “Red Flags” identity theft rules are slated to take effect on June 1. In an effort to address the growing risk of identity theft, the FTC released rules in November 2007 requiring all financial institutions and “creditors” (including health care providers) to develop and implement a written program to protect consumers by identifying potentially suspicious “red flags” that may signal identity theft. The ACC, the American Medical Association (AMA) and other medical associations have strongly opposed the inclusion of physicians as creditors and have repeatedly been able to delay the rule’s implementation date. Most recently, the AMA, the American Osteopath Association (AOA) and the Medical Society of the District of Columbia filed a lawsuit on this point.