10/01/2020
What You Need to Know About… Medicare Revalidations
Chiropractors Must Revalidate Every Five Years
As you may know, all Medicare providers are required to renew their enrollment record periodically to maintain their billing privileges. Medicare calls this process “revalidation.” Generally, chiropractors and other providers are required to revalidate every five (5) years. CMS also reserves the right to require “off-cycle” revalidations outside of that five-year period.
PECOS (Provider Enrollment, Chain, and Ownership System)
Medicare’s Provider Enrollment, Chain, and Ownership System (PECOS) supports the Medicare Provider and Supplier enrollment process by allowing registered users to securely and to electronically submit and manage Medicare enrollment information. It is the most efficient way to submit your revalidation, allowing providers to:
- Review information currently on file
- Upload your supporting documents
- Electronically sign and submit your revalidation online, eliminating the need to mail anything
Additionally, PECOS is tailored to ensure that only information that is actually relevant to the application is submitted.
Due Date. Providers can find their revalidation due date by searching the Medicare Revalidation List. Revalidation due dates are posted by CMS six to seven months in advance. A due date of “TBD” means that CMS has not yet set the provider’s revalidation due date.
Failure to Revalidate. Failing to revalidate prior to the due date could result in a hold on Medicare reimbursement or even the deactivation of Medicare billing purposes, which would require the provider to re-submit a complete Medicare enrollment application to reactivate billing privileges. Also, Medicare will not reimburse providers for services provided during the deactivation period.
Exemptions. There are no exemptions from revalidation, or extensions. Providers will receive notification from their Medicare Administrative Contractor through email or U.S. postal mail allowing time to revalidate before the due date (usually about three or four months prior to the due date).
However, like the State of Michigan with license renewal, while notifications are sent, providers themselves are responsible for keeping track of their due date. Failure to receive notification is not a valid excuse for failure to revalidate prior to the due date.
CMS recommends revalidating within three months of your revalidation due date, even if you have not received a notification. They also advise providers not to revalidate if their due date is more than seven months away (unless they have received a revalidation notice). Unsolicited revalidations will be returned.
Medicare Revalidation and COVID-19
CMS Has Temporarily Postponed All Revalidation Actions During the Public Health Emergency Associated with the COVID-19 Pandemic
The Centers for Medicare and Medicaid Services (CMS), exercising its authority under the Social Security Act to offer flexibilities with Medicare provider enrollment to support the 2019-Novel Coronavirus (COVID-19) national emergency, has postponed all revalidation actions. According to CMS’ 2019-Novel Coronavirus (COVID-19) Medicare Provider Enrollment Relief Frequently Asked Questions:
“CMS is temporarily ceasing revalidation efforts for all Medicare providers or suppliers. During the COVID-19 PHE [Public Health Emergency], CMS will not issue any new revalidation notices, deactivate providers who fail to respond to revalidation requests, or update the Medicare Revalidation Tool at https://data.cms.gov/revalidation with new revalidation due dates. Revalidation applications submitted to your MAC will continue to be processed but not in an expedited manner. Upon the lifting of the public health emergency, CMS will resume revalidation activities.”
The MAC Insurance Relations Committee recommends that all providers familiarize themselves with this FAQ document.