CMS has issued an updated MLN Article SE1126 with information regarding mandatory enrollment revalidation based upon the previous MLN Article MM7350. The ACA requires enhanced enrollment procedures effective March 25th of this year based upon identified categorical risk to the Medicare program. Physical Therapists in Private Practice were elevated to the “moderate risk category” and additional screening measures have been in place for all physical therapists enrolling after March 25, 2011. Additionally this enhanced screening criteria is being applied to physical therapists who submit a “change of information”. For example a therapist transfering from one clinic to another, even within the same company, may find their transfer under review if the NPI number of the clinic is different.
The enhanced enrollment procedures have also affected Comprehensive Outpatient Rehabilitation Facilities (CORFs), who have also been placed in the CMS moderate risk category. While providers are advised to wait for their Medicare Administrative Contractor (MAC/FI or Carrier) to notifiy them to proceed with enrollment revalidation, it should be noted that CORFs in Florida may be subject to “out of cycle” revalidation requests that according to the Program Integrity Manual may be as a result of suspected fraud in the geographic area. Several Florida CORFs have also reported that filing of a change of information form (855 or via PECOS) has triggered enhanced scrutiny from the Zone 7 ZPIC including site visits and 100% prepayment review of claims.