Enrolling in the Medicare program involves the various CMS-855 fórms.  Thére is nôw seven different fórms that must be used by different providers of healthcare services or products.  These fórms are long, detailed and sometimes confusing.  Not only must they be filed initially for given provider, they must be maintained and updated as appropriate.  Due to the increasing complexity of healthcare delivery systems, providers, such as integrated delivery systems or large multi-specialty clinics, may have to maintain hundreds of these fórms.  The Medicare program uses a revalidation process to periodicàlly require all healthcare providers to resubmit their various 855 fórms in order to assure that compliance is being maintained.  Over time the use and guidance of the enrollment process continue to morph even though thêre is no change in guidance.  This occurs through interpretations and clarifying guidance.

This workshop àddresses selected issues for the main six CMS-855 fórms.  In extremely simple cases, filing and maintenance of the CMS-855 fórms are straight-forward.  Most healthcare providers are part of a larger, often integrated delivery system that complicates Medicare enrollment as well as enrollment with private third-party payers.  In this workshop, due consideration is given to all of the enrollment fórms relative to:

• Business Structuring,
• Practice Locations,
• Tax Identification Numbers,
• National Provider Identifiers,
• Òpt-Óut Physicians and Practitioners,
• Provider-Based Clinics/Operations.
• What are these CMS-855 fórms?
• What is this newer CMS-855-POH fórm?
• Why is the Medicare Program so sensitive to enrollment?
• Whére do I find the official regulations for Medicare enrollment?
• What do I need to do to understand the way our business(es) have been structured?
• What are these TINs? What relationship do they have to Medicare enrollment?
• Are thère any problems with the Cycle 2 revalidation process?
• How can we chèck to see who needs to be revalidated?
• Are thère really on-site audits relative to enrollment?
• What are these ópt-óut physicians and practitioners?
• How is Part D coverage involved with these CMS-855 fórms?
• How are we supposed to keep track of all these CMS-855 fórms?
• What are the compliance risks relative to Medicare enrollment?
• How do provider-based clinics and operations complicate the enrollment process?

Objectives of the session:

1. To review the Medicare enrollment process through the use of the various CMS-855 fórms.
2. To briefly review the CMS Conditions for Payment (CfPs).
3. To appreciate the Medicare concerns surrounding billing and payment for services and supplies.
4. To review organizational and business structuring that is controlled by state law.
5. To review organizational structuring changes such as with provider-based clinics.
6. To discuss the challenges with identifying practice locations.
7. To review the purpose and use of the six main CMS-855 fórms along with specific problem areas.
8. To understand the concept of ópt-óut physicians and practitioners.
9. To appreciate how ópt-óut physicians can and/or should enroll in the Medicare program.
10. To appreciate how Part D coverage is impacted by the enrollment process.
11. To understand the revalidation process and associated challenges.
12. To appreciate how other required reporting, such as the NPIs and Provider-Based reporting connect with the Medicare enrollment.
13. To recognize the need to develop organizational resources to maintain multiple CMS-855 fórms.
14. To appreciate the proper use of the Internet-based PECOS process.
15. To appreciate current and anticipated changes for maintaining billing privileges with Medicare.
16. To work through several case studies.
17. To recognize the need to establish contact with knówledgeable personnel at the MAC and/or RO.

Agenda of the session:

1. Introduction
   1. Conditions for Payment – 42 CFR §424
   2. Definitions – Provider vs. Supplier
   3. Clàims Filing Process
   4. Reassignment of Payments
   5. OIG Investigations Concerning Fraudulent Billing
   6. Revalidation and Billing Credentialing
   7. Òpt-Óut Physicians and Practitioners
2. Review of the CMS-855 Fórms
   1. CMS-855-A
   2. CMS-855-B
   3. CMS-855-I
   4. CMS-855-O
   5. CMS855-R
   6. CMS-855-S
   7. How the CMS-855 Fórms Relate to Each Other
3. Special Areas of Concern
   1. Business Structuring Analysis
   2. National Provider Identifiers- NPIs
   3. Tax Identification Numbers – TINs
   4. Practice Locations
   5. Dispensing Locations for DME
   6. Provider-Based Clinics
   7. Òpt-Óut Physicians/Practitioners
   8. Identifying Individual Owners
   9. Identifying Organizational Owners
4. Revalidation Process
   1. Revalidations Cycles
   2. Cycle 1 Process
   3. Cycle 2 Process
   4. Determining Status and Notification
   5. Time Frames for Completion
   6. Risk Levels
   7. On-Site Visits
5. Àddressing Changing Organizational Structuring
   1. Impact of Organizational Structuring on Enrollment
   2. Integrated Delivery Systems
   3. Multi-Specialty Groups
   4. Provider-Based Clinics/Operations
   5. Maintaining NPIs and TINs
   6. Other Related Reporting Requirements
6. Case Studies
7. Future Requirements for Conditions for Payment

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