On February 22, the Centers for Medicare and Medicaid Services (CMS) announced its intention to further enhance CMS’s ability to screen providers and suppliers enrolling or currently enrolled in Medicare for compliance with Medicare enrollment requirements. Specifically, CMS will strengthen existing screening measures by increasing the number of site visits to Medicare enrolled providers and suppliers, enhancing address verification software in CMS’s Provider Enrollment Chain and Ownership System (PECOS), analyzing enrollment data to identify and deactivate certain providers who have not billed Medicare within the last 13 months, and monitoring and identifying potentially invalid addresses contained in initial enrollment applications.

Increased site visits. CMS has increased the number of site visits it will make to verify enrollment information submitted. CMS plans to target enrollees receiving high reimbursements and located in identified high risk geographic areas.

Enhanced PECOS address verification software. New address verification software will flag addresses that may be vacant, commercial mail reporting agencies or otherwise invalid. CMS has indicated that addresses so flagged may be subject to additional CMS site visits.

Deactivation of non-billing providers and suppliers. Beginning in March, CMS will analyze enrollment data on a monthly basis to identify and deactivate certain enrollees that have not billed Medicare in the last 13 months, with the exception of certain providers and suppliers who may be exempt from deactivation for non-billing.

Identification of potentially invalid addresses. CMS has already started validating provider and supplier enrollment practice location addresses by comparing addresses currently on file with CMS against the U.S. Postal Service address verification database. This analysis will occur on a monthly basis and will assist CMS in identifying addresses that become vacant or non-operational after initial enrollment.

Because CMS will be increasing its Medicare enrollment screening efforts, which could include enforcement for non-compliance with Medicare enrollment requirements, Medicare enrollees should remain diligent in maintaining correct information on file with their Medicare administrative contractors by filing the appropriate 855 forms if, for example, a provider or supplier makes changes to facility locations, undergoes site closings or openings, or makes changes to facility hours of operation.

*Wendy Wright is admitted only in North Carolina. Her practice is supervised by principals of the firm admitted in the District of Columbia.