Supplier Medicare Enrollment Information Revalidation

Dear Supplier,

Every three years, Centers for Medicare and Medicaid Services (CMS) requires suppliers to revalidate their Medicare enrollment information. Suppliers are required to either update or confirm all their information in their records, including but not limited to practice location, surety bond, and insurances. CMS usually posts revalidation dates 6-7 months in advance of the due date and the National Provider Enrollment (NPE) contractor notifies suppliers via mail of the need for revalidation. Suppliers generally have about 90 days to respond to the revalidation request once one is issued.

If a supplier fails to respond to the revalidation notice or fails to respond timely, the supplier’s billing privileges may be deactivated. If the supplier submits a reactivation request, the supplier will maintain their original PTAN, however, they will have a new effective date. The supplier may not be paid for services rendered during the period of deactivation (between deactivation date and new effective date). This can cause a gap in supplier’s reimbursement. Additionally, a reactivation request can take months to be processed and during this time, the supplier may not receive any payment from Medicare for services provided after deactivation date. The deactivation may also accelerate Medicare’s collection efforts on overpayments by swiftly referring a debt or notice of their intent to refer the debt to your surety bond company.

CMS Stay of Enrollment

CMS is also working with the NPE contractors to implement a program called “Stay of Enrollment” for DMEPOS supplier. If implemented as proposed, stay of enrollment should be fully implemented for suppliers by the end of Q4 2024. Once implemented, suppliers who fail to respond to the revalidation notice, or fail to revalidate timely, will be placed in a stay of enrollment instead of deactivation. The stay will last no more than 60 days and during the stay the provider will remain enrolled in Medicare, but claims submitted with a date during the stay period will be rejected by Medicare. Medicare may also hold payments during the stay. If the supplier timely submits the revalidation after being placed on the stay of enrollment, the stay will be lifted, and if the revalidation is approved, there will be no gap in the provider enrollment. If the supplier fails to revalidate during the period of the stay, their billing privileges maybe be deactivated.  

Tips to avoid deactivation

To avoid the inconvenience of a deactivation or stay of enrollment, I highly recommend suppliers take a more proactive approach in ensuring revalidations are completed timely and accurately. Here are some practical recommendations:

• Make sure your address is updated with Medicare. If you move or change your address, it is important that you notify Medicare as soon as possible but no later than 30 days. Revalidation notice sent to the wrong address can definitely result in failed or delayed revalidation. An undeliverable returned mail to Medicare might also result in other adverse actions such as hold on future electronic payments.
• Orient your staff who opens the mail to the importance of certain letters from Medicare and even more specifically the NPE contractors. All written correspondence should be immediately routed to the appropriate individual within the organization for timely processing.
• If you have not completed your revalidation in the last three years, I would suggest reaching out to your NPE contractors to ensure you do not have a pending revalidation. If your practice location is located west of the Mississippi River, you should contact Palmetto GBA at NPE West (palmettogba.com) and east of the Mississippi River suppliers should contact Novitas Solutions at DMEPOS Contact Us (novitas-solutions.com). Suppliers can also check their CMS Medicare Revalidation List | CMS Data to see if they have a pending revalidation. Suppliers can search by NPI number or organization name.
• Please ensure all the information is accurate when submitting a revalidation. Please ensure your licenses, surety bond, insurances are all current and if expiring soon, include renewals in your submission.
• After submitting your revalidation request, suppliers should follow up with the NPE contractor periodically to ensure, if they have issued a development letter for additional documentation that you can respond timely to remedy the deficiencies. Failure to respond timely to a development letter will result in a deactivation. Suppliers cannot solely rely on a notification from the NPE contractors as we have heard of many instances where such notification wasn’t received timely or received at all. It could be an email that a supplier’s email firewall rejected or a snail mail that was just never delivered.
• Be prepared for the site visit. I have seen a lot of deactivations as result of failed site visits. Self-audits should be performed to ensure the supplier is compliant with the Supplier Standards and the Quality Standards. Have constructive dialog with the site inspector and explain any discrepancies you believe might be problematic. For example, if you are an Orthotic and Prosthetic (O&P) supplier, clarify why you would not have or required to have a rent purchase option letter.  

Temporary pause in revalidation

Ending with good news. CMS has announced a temporary pause in revalidations due between November 2024 and April 2025. The NPE will resume notification and processing in May 2025. The temporary pause will enable the NPE contractors to catch up on the backlog of revalidations.

In summary, suppliers are encouraged to be vigilant and proactive in ensuring their revalidation is timely completed. Sadly, the post office mailing system is not always reliable; therefore, proactive measures such checking the CMS revalidation list and/or reaching out to your NPE contractor is recommended.