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CMS Will Provide Temporary Provider Enrollment Flexibilities

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03/23/2020

CMS released an FAQ Document explaining how it will use its authority under Sec. 1135 of the Social Security Act to provide flexibilities with its Medicare provider enrollment requirements during the COVID-19 Public Health Emergency (PHE).

Expedited Provider Enrollment

During the PHE, CMS is allowing physicians and non-physician practitioners to temporarily enroll as Medicare providers using a toll free hotline provided by their MAC. The numbers are included in the CMS FAQ document.

To initiate temporary billing privileges, practitioners will be asked to provide limited information, including, but not limited to, Legal Name, National Provider Identifier (NPI), Social Security Number, a valid in-state or out-of-state license, address information and contact information (telephone number).

MACs should be able to complete the expedited enrollment process over the phone. Enrollments would be effective as early as March 1, 2020.

Providers can enroll their homes as distant site locations for telehealth services using the hotline.

CMS will also temporarily waive the following screening requirements:

  • Criminal background checks associated with fingerprint-based criminal background checks (to the extent applicable).
  • Site visits.
  • Postpone all revalidation actions.

The expedited process does not impact enrollment applications submitted to MACs prior to March 1st using the regular enrollment process.

State Licensure for Medicare Providers

CMS will also provide individual waivers from the Medicare requirement that a physician or non-physician practitioner must be licensed in the State in which s/he is practicing. Four criteria must be met for the waiver:

  • The physician or non-physician practitioner must be enrolled as such in the Medicare program,
  • The physician or non-physician 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.

However, the state must also waive its licensure requirements. CMS’ waivers do not supersede State or local licensure requirements or any requirement specified by the State or a local government. Those requirements would continue to apply unless waived by the State. Therefore, the State also would have to waive its licensure requirements, either individually or categorically, for the type of practice for which the physician or non-physician practitioner is licensed in his or her home State.

Suspending Revalidation Activities

CMS is temporarily ceasing revalidation efforts for all Medicare providers or suppliers. Upon the lifting of the public health emergency, CMS will resume revalidation activities.