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CMS makes changes to provider enrollment in response to COVID-19

Mar 23, 2020

On March 23, 2020, the Centers for Medicare & Medicaid Services (CMS) released an FAQ on Medicare provider enrollment relief, noting several key changes aimed at streamlining and expediting provider enrollment in light of COVID-19.

Physicians and non-physician practitioners may now enroll and receive temporary billing privileges without certain fingerprint-based criminal background checks and site visits. These physicians and non-physician practitioners may enroll by calling specially-created, toll-free hotlines at each of the Medicare Administrative Contractors (MACs), which are listed in the FAQ linked above. CMS anticipates that the MACs will be able to approve or reject requests for temporary Medicare billing privileges during the phone conversation, and physicians and non-physicians may be assigned an effective date as early as March 1, 2020. Once the public health emergency declaration is terminated, any physician and non-physician practitioner who received temporary billing privileges will be required to submit a CMS-855 enrollment application and meet all typical enrollment requirements at that time. 

CMS has ordered that any pending or new applications from all other providers and suppliers, including durable medical equipment (DME) suppliers, be expedited by the MACs. CMS notes that all clean web applications will be processed within 7 business days and all clean paper applications will be processed within 14 business days. For all enrollment applications received on or after March 1, 2020, the following screening requirements will be waived: application fees, site visits, and certain fingerprint-based criminal background checks. Pending applications that were submitted to a MAC prior to March 1, 2020, will be processed in line with existing timeframes (generally, 45 days for web applications and 60 days for paper applications).

Further, all revalidation efforts are postponed until further notice for all Medicare providers or suppliers, and CMS is also postponing DME accreditation and reaccreditation timetables. CMS notes that DME suppliers should still comply with accreditation requirements but formal accreditation will be postponed.

With regard to licensure rules, CMS is allowed to waive, on an individual basis, the Medicare requirement that a physician or non-physician practitioner must be licensed in the state in which s/he is practicing. The waiver is not available, however, unless all of the following four conditions are met:

  1. the physician or non-physician practitioner must be enrolled in the Medicare program,
  2. the physician or non-physician practitioner must possess a valid license to practice in the state which relates to his or her Medicare enrollment,
  3. the physician or non-physician practitioner is furnishing services – whether in person or via telehealth – in a state in which the emergency is occurring in order to contribute to relief efforts in his or her professional capacity, and
  4. the physician or non-physician practitioner is not affirmatively excluded from practice in the state or any other state that is part of the 1135 emergency area.

It should be noted that the above has no effect on state or local licensure requirements. Therefore, a provider must still meet those state-specific requirements unless those requirements have been waived through an emergency declaration or other executive action in that state.

Finally, distant site practitioners may furnish Medicare telehealth services from their home, but the home address must be added to the practitioner’s Medicare enrollment. A practitioner can add his/her home address to the practitioner’s Medicare enrollment file by using the MAC provider enrollment hotline referenced above. If the physician or non-physician practitioner reassigns his/her benefits, the clinic/group practice must add the practitioner’s home address to the clinic’s/group’s enrollment record, and may do so by calling the applicable MAC’s provider enrollment hotline.

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