By George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law
We continue to receive calls from physicians and other Medicare providers who have had their Medicare billing privileges revoked or terminated because their address information is not up to date or is incomplete. It is a must that you include a physical address at which your business operates so that if the Medicare Administrative Contractor (MAC), the Recovery Audit Contractor (RAC), or the Zone Program Integrity Contractor (ZPIC) attempts a site visit, they can find you and complete the site visit. Leaving out a suite number, having the incorrect city or suite listed, having a locked entranceway or gate so that the auditors cannot get in, have all lead to revocation of Medicare billing privileges. This can have devastating results to the business.
Frequently the physician or other Medicare Provider has recently relocated and the record has not been updated yet. Other times, a post office box or other address is used instead of an actual physical address. Often moving from one hospital to a different hospital leaves your information listed incorrectly. Sometimes the street address is not complete or is incorrect. Sometimes it is just a matter of a typographical error being made by whoever enters your addresses.
Just having a letter returned to the contractor because of an incorrect address can initiate this action. You will be held individually responsible, regardless of this, even if you use an independent contractor or someone else to make your Medicare filings and keep them up to date.
The basis for the revocation is 42 CFR424.535(a)(5) and 424.535(a)(9) Medicare Provider is considered to be non-operational at the practice location on record with the Centers for Medicare and Medicaid Services (CMS).
You can easily check your own information to be sure it is correct, and you should do so. Your addresses should be located online in the Provider Enrollment, Chain and Ownership System (PECOS). You can visit the website by clicking here.
For more information, click here.
You can also check online at the National Plan and Provider Enumeration System (NPPES) by clicking here.
Do this now!
If you receive a letter or any other indication that your Medicare billing privileges have been revoked or terminated, you must act immediately. Contact an experienced health lawyer to assist you immediately. Don’t wait, you will regret it if you do.
Contact Experienced Health Law Attorneys.
The Health Law Firm routinely represents pharmacists, pharmacies, physicians, nurses and other health providers in Centers for Medicare and Medicaid Services (CMS) investigations, Medicare Audit defense, regulatory matters, licensing issues, litigation, inspections and audits involving the DEA, Department of Health (DOH) and other law enforcement agencies. Its attorneys include those who are board certified by The Florida Bar in Health Law as well as licensed health professionals who are also attorneys.
About the Author: George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law is an attorney with The Health Law Firm, which has a national practice. Its main office is in the Orlando, Florida, area. www.TheHealthLawFirm.com The Health Law Firm, 1101 Douglas Avenue, Altamonte Springs, Florida 32714, Phone: (407) 331-6620.
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