06/18/2013    Name Withheld (FL)

Medicare Enrollment Revocation for Providers Occurring for Reasons You May Not Suspect - Be Proactive!

Revocation of Medicare enrollments are occurring
for physicians and other providers not only in
jurisdictions where they previously practiced;
but, as a result of those enrollments in prior
Medicare jurisdictions, revocations are now
occurring for their Medicare enrollments where
they currently practice. Revocation is a serious
problem resulting not only in termination of
revenue; but re-enrollment in the Medicare
program in these cases is barred for ONE YEAR.

How is this happening? Here is an example; and
you will agree, it happens all the time, thus
being an issue that EVERY practice will need to
pay attention to and be proactive in preventing!

Dr. Jones was doing his fellowship in Minnesota;
and as required, had a valid medical license in
Minnesota. During his fellowship, his employer
enrolled him in Medicare Part B in the Minnesota
jurisdiction in order to bill Medicare for valid
services.

When Dr. Jones completed his fellowship, he then
left Minnesota and came to Florida to work for a
Florida entity. When he left Minnesota, he never
intended to maintain an active medical license in
Minnesota; and when the time came to renew the
license, he did not renew it.

In addition, when he left the Minnesota employer,
the employer did not terminate his reassignment;
and Dr. Jones Medicare enrollment in Minnesota
remained an active enrollment. Dr. Jones could
have initiated a voluntary termination of his
Minnesota Medicare enrollment; but he was not
aware of Medicare enrollment rules.

State medical licensing boards share information
with Medicare contractors. Following the
expiration of Dr. Jones medical license in
Minnesota, the Minnesota Medicare contractor
received information from the board indicating
Dr. Jones’ medical license had expired. The
Medicare contractor revoked Dr. Jones Medicare
enrollment. Dr. Jones never received any
communication notifying him of the revocation.

If a provider has an enrollment revoked, they
then have an obligation to report this “adverse
legal” action to their current Medicare
contractor. Dr. Jones was now working in Florida
and enrolled in Florida Medicare. Not being aware
of the revocation, he made no disclosure to
Florida Medicare regarding the Minnesota
revocation.

Medicare contractors are able to share
information through the PECOS enrollment system.
Florida Medicare then became aware of Dr. Jones
revocation due to an expired medical license in
Minnesota.

Recently Dr. Jones received a letter from Florida
Medicare indicating his Florida enrollment would
be revoked since he did not disclose the
Minnesota revocation! A Corrective Action Plan
(CAP) to prevent the revocation in Florida has
been filed with Florida Medicare and is currently
in process.

Should you have a provider who faces this type of
situation, it is imperative to immediately file a
corrective action plan with the Medicare
contractor to prevent the revocation from
finalizing. Follow up regularly to insure the CAP
application is in process and continue the
appeals process if it becomes necessary.

Name Withheld (FL)

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