Medicare Provider Enrollment Flexibilities during the COVID-19 Public Health Emergency

During the COVID-19 Public Health Emergency (PHE), the Centers for Medicare and Medicaid Services (CMS) is exercising its authority under Section 1135 of the Social Security Act to offer flexibilities for Medicare provider enrollment. Here is a brief overview of some of those relaxed, temporary guidelines.

Provider Enrollment Hotlines

Providers who need to enroll with Medicare can do so on a temporary basis over the phone. CMS has established toll-free hotlines at each of the Medicare Administrative Contractors (MACs) to allow physicians and non-physician practitioners to initiate temporary Medicare billing privileges.

To initiate temporary billing privileges, providers will need to provide the following limited information: Legal Name, National Provider Identifier (NPI), Social Security Number, a valid instate or out-of-state license, address information, and contact information (telephone number). Fingerprint-based criminal background checks and site visits are being waived for the temporary enrollment.

The MAC will attempt to screen and enroll providers over the phone and will notify them of their approval or rejection of temporary Medicare billing privileges during the phone conversation. A follow up letter also will be sent via email to communicate the approval or rejection of the provider’s temporary Medicare billing privileges. The effective date can be as early as March 1, 2020, and will extend through the end of the public health emergency.

Once the public health emergency declaration has been lifted, providers with temporary enrollments will be asked to submit a complete CMS-855 enrollment application in order to establish full Medicare billing privileges. Failure to respond to the MAC’s request within 30 days of the notification will result in the deactivation of the temporary billing privileges, and no payments can be received for services provided after the deactivation of temporary billing privileges.

To find the hotline for your MAC, check out page two of the 2019-Novel Coronavirus (COVID-19) Medicare Provider Enrollment Relief Frequently Asked Questions (FAQs).

Practice Locations

The Provider Enrollment Hotlines mentioned above may also be used by physicians and nonphysician practitioners to report a change in practice location.

For providers offering telehealth services from their home, there are no payment restrictions on furnishing Medicare telehealth services from their homes, and practitioners are not required to update their Medicare enrollment with the home location. CMS recommends listing the home address on the claim to identify where the services were rendered, noting that the discrepancy between the practice location in the Medicare enrollment and the practice location identified on the claim will not be an issue for claims payment.

State Licensure

The Secretary for Health and Human Services (HHS) has authorized CMS to waive the Medicare requirement that physician or non-physician practitioners must be licensed in the State in which they are practicing when the following four conditions are met:

the physician or nonphysician practitioner must be enrolled as such in the Medicare program,
the physician or nonphysician practitioner must possess a valid license to practice in the State which relates to his or her Medicare enrollment,
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
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’s important to note, however, that an 1135 waiver granted by CMS cannot supersede State or local licensure requirements or any requirement specified by the State or a local government as a condition for waiving its licensure requirements. Those requirements would continue to apply unless waived by the State.

Revalidation

CMS is temporarily ceasing all revalidation efforts for Medicare providers or suppliers. Once the public health emergency has been lifted, CMS will resume revalidations.

Terminating Opt-Out Status

Under the 1135 waiver authority, CMS is waiving opt-out requirements to allow practitioners to

terminate their opt-out early and enroll. Opted-out physicians and practitioners can contact their MAC through the provider enrollment hotline to terminate their opt-out and establish Medicare temporary billing privileges.

For more information on Medicare Provider Enrollment flexibilities during the COVID-19 Public Health Emergency, check out CMS’s 2019-Novel Coronavirus (COVID-19) Medicare Provider Enrollment Relief Frequently Asked Questions (FAQs).