Medicare Providers: Make Sure Medicare Has Your Correct Address; Make Sure You Complete CMS Forms 855I Correctly
Wednesday, October 29, 2014
By George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health LawWe are constantly consulted by and retained to represent physicians, medical groups, pharmacies, durable medical equipment (DME) distributors and other Medicare providers on issues relating to deficiencies from site visits and inspections by Medicare contractors and on notices of termination of Medicare billing privileges.
Results of Termination from the Medicare Program.These are extremely serious issues that could cause you to be terminated from the Medicare Program. This may not only cause you to lose income or go out of business; it may also cause you to be terminated from state Medicaid programs, be terminated from insurance panels, lose your certifications from your credentialing organizations and also your hospital or nursing home clinical privileges.Yet the mistakes which most often result in these dire consequences are simple and easy to avoid or correct. Don't let a simple error destroy your business and career.Top Three Problems Causing Termination.The mistake we see most often that results in adverse treatment by the Centers for Medicare and Medicaid Services (CMS) or its Medicare Administrative Contractors (MACs) is a change of address that has not been submitted to Medicare.The second most frequent mistake we see is an error in the address, such as an incorrect suite number, transposed digits in the street address or incorrect zip code in the billing address.The third most frequent problem we see is that there are different addresses used for the provider that are inconsistent. For example, an address listed as the location of the provider's corporation or company on the Secretary of State's website may be different from that which Medicare has on file.You should carefully check your National Plan and Provider Enumeration Entry (NPPES) listing online and your Provider Enrollment, Chain and Ownership System (PECOS) listing online to make sure every address for you listed is correct. Also check your corporate, company or business entity records with your Secretary of State's office and make sure that the addresses listed for your business are the same as you have listed with Medicare. It is also a good idea to make sure your website, Internet listings and telephone directory listings are current and consistent.Remember, you will have at least three (3) addresses listed on these, including: (1) Location of business; (2) Mailing address of business, and (3) Mailing address for payments. Make sure all are current, accurate and consistent with other addresses you have on file.Fourth Most Frequent Problem is Failing to use your Correct Provider Name with Medicare.It is difficult to believe but there are apparently many people in business who do not understand the legal necessity of using their full, correct business name everywhere, especially with Medicare. Many businesses use a different fictitious business name, either registered or unregistered. However, this does not alter the fact that the business may be organized as a corporation, a limited liability company, or another form of business entity.If your business entity includes a middle initial or name, use it. If your business entity has an "Inc." or "LLC," at the end of it, include this. If your business entity is incorporated in one name but uses a different name for its business, be sure you always use the accurate business entity name and note that you have a different fictitious business name (sometimes called a "D/B/A" or "doing business as" name). If you are an individual and routinely use a "Jr." or "III" suffix, be sure this is included. ALWAYS USE YOUR COMPLETE NAME.CMS Forms 855I are routinely rejected when an inaccurate or incomplete business name is used on them.
Pay Attention to the Details.For any aspect of your business, in order to be successful, you must pay attention to the details. This adage is applicable to the Medicare Program. If you do not want action taken to terminate your Medicare billing privileges, you must be attentive to such details as I have discussed above.Comments?Have you ever encountered a pitfall on your Medicare forms that resulted in program termination or discipline? Did you know that small mistakes such as an incorrect address could have such serious repercussions? Please leave any thoughtful comments below.Don't Wait Until It's Too Late; Consult with a Health Law Attorney Experienced in Medicare and Medicaid Issues Now.The attorneys of The Health Law Firm represent healthcare providers in reversing termination of Medicare billing privileges, preparation of corrective action plans (CAPs), requests for redetermination, hearings on Medicare terminations, Medicare audits, ZPIC audits and RAC audits throughout Florida and across the U.S. They also represent physicians, medical groups, nursing homes, home health agencies, pharmacies, hospitals and other healthcare providers and institutions in Medicare and Medicaid investigations, audits, recovery actions and termination from the Medicare or Medicaid Program.For more information please visit our website at www.TheHealthLawFirm.com or call (407) 331-6620 or (850) 439-1001.
About the Author: George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law. He is the President and Managing Partner of 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 Ave., Altamonte Springs, FL 32714, Phone: (407) 331-6620.
Tag Words: Medicare, Medicare providers, Medicare audits, site visits, Durable Medical Equipment (DME), Florida Medicare, Medicare defense, Centers for Medicare and Medicaid Services (CMS), CMS Forms, CMS Forms 855I, Medicare address, business address, defense attorney, defense lawyer, Medicare billing privileges, Medicare exclusion, the Medicare program, National Plan and Provider Enumeration Entry (NPPES), Provider Enrollment Chain and Ownership System (PECOS), Medicare Administrative Contractors (MAC's), Medicare address change, business address, medical office, physician, health law, The Health Law Firm
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