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07/14/2017    Paul Kesselman, DPM

Screwed by Palmetto GBA NSC (Richard Rettig, DPM)

I have provided an in-depth personal response
Drs. Rettig and Kerner who were unceremoniously
deactivated by the NSC. Unlike when private
third-party payers dump you, NSC does allow you
to re-activate. There is a lesson to be learned
by the misfortunes of these two providers, both
of whom will be able to re-establish (Dr.
Rettig already has) their enrollment with the
NSC- but first some background:

The NSC has a standard program of 3-year
renewals and they claim that they fulfilled
their due diligence by mailing you a renewal
letter in a very noticeable yellow envelope.
The 3-year period was chosen as an initiative
by which they claim they can cut down on fraud
and abuse and is mandated by CMS which oversees
the NSC. Beyond that, the NSC asserts it is
your responsibility to keep up with your
enrollment.

In this day and age, it seems that is a rather
antiquated method by which to keep up to date
with providers and I agree that the NSC should
be updating their enrollment contact methods by
including email (which is almost free).
However, this too is not totally risk free as
many times important email is either blocked or
is automatically sent to spam or junk folders.

To that end the NSC is steadfast on continuing
to only contact you once via snail mail. They
have however to their credit established a
website where you can track the date you may be
required to re-enroll. This can be found at:
https://data.cms.gov/revalidation

Here you will be asked to enter the NPI number
used with DME claims and you will be provided
up to six months warning of your renewal.

All of us should agree that the NSC must cut
out fraudulent providers but not to the extent
that it harms the honest hard working ones.

So it seems that CMS has thus put the onus on
all of us. Just another awful policy we are
helpless to overturn. However one should not
take this as specifically targeting DPM's.
This is an issue for the entire supplier
community. I dare say it likely happen with
your local Medicare carrier where the impact
may be even more disastrous.

On the upside, I did attempt to intercede on
the behalf of both Drs. Kerner and Rettig by
inquiring with a high official at the NSC.
They informed me that: "Reactivations are
retroactive to the original deactivation date.
Once reactivated the supplier will be able to
submit claims for the time they were
deactivated." Dr. Rettig has already received a
reactivation letter as upon learning of this
issue contact the NSC and submitted his
application via PECOS. Thus, Dr. Rettig's
billing privileges have been reactivated
retroactive to the initial date of deactivation
and he may retroactively bill for any services
since his deactivation notice.

Thus if you find yourself in the same position
as Drs. Kerner and Rettig, you may continue to
provide DME and your deactivation will be
removed and your re enrollment will be
retroactive to the date of deactivation.

However, one should hold your claims and
submit them once your enrollment is
reactivated. Therefore, in the long run you
won't be losing any revenue. In the short term
however you will be forced to hold onto claims
and this could have an impact on your cash flow
as it may take up to 3 months or more to get
through the application process. Obviously, if
you fail the re-activation process then you
could have some major revenue losses.

To reiterate, one should periodically check the
date(s) of their previous re enrollment with
the NSC to determine whether or not one is
close to a renewal date.

It is equally important to use the NSC website
located at: https://data.cms.gov/revalidation
in order to determine whether your NPI is up
for renewal.

Paul Kesselman, DPM, Woodside, NY

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