JO - Health Care Compliance Association

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American Health Lawyers Association and Health Care Compliance Association presents FRAUD AND COMPLIANCE FORUM September 25-27, 2006 Renaissance Harborplace Hotel • Baltimore, MD PLAN NOW TO ATTEND Visit: www.hcca-info.org for more information Don't miss the Fraud and Compliance Forum! The program will provide legal analysis and practical compliance guidance on issues including: • Fraud and Abuse Issues for Physicians, Long Term Care Facilities, Managed Care Organizations, Hospitals and Health Systems and Pharmaceutical Manufacturers • Stark II Phase II Regulations and Fair Market Value • EMTALA • Legal Ethics • Research Compliance and Billing • Auditing and Monitoring Compliance Plans • Internal Investigations has provided sponsorship in support of this program. To register visit us online at: www.hcca-info.org For questions call HCCA at: (888) 580-8373 SAVE THE DATE! Continuing Education Credits: AAPC • ACHE • AHIMA • HCCB • NASBA • MCLE September 2006 28 Health Care Compliance Association • 888-580-8373 • www.hcca-info.org
New Medicare enrollment regulations ...continued from page 27 accept the assignment of the seller’s provider number, the new regulations allow for deactivation of the billing number any time before the final transference of the provider agreement to the buyer, if the buyer fails to submit what is required within 30 days of the change of ownership. With respect to a change of ownership or control involving suppliers, appropriate CMS 855 forms must be submitted within the 30 days immediately following the change. Conclusion It is strongly advisable to become familiar with the new CMS 855 forms, the information required to be reported using these forms, and the supporting documentation to be sent to CMS. This is certainly important for new providers or suppliers, and existing providers and suppliers when they are called upon to complete the CMS 855 form for the first time as part of the revalidation process, or as part of a change of ownership transaction. It is particularly important for existing providers and suppliers who have never completed a CMS 855 form and have changes that would require updating the enrollment file. Existing providers, especially those not familiar with the CMS 855 process, may not be aware that they are required to report certain changes that occur during the ordinary course of conducting their business affairs. Any changes in the categories of information required on these forms—even if the forms had never previously been submitted, and the provider or supplier had never previously reported such information to CMS—must now be reported using the new forms. If unfamiliar with the reporting requirements, a provider or supplier may not realize the broad scope of information that CMS requires to be maintained in its enrollment files and used by CMS for its monitoring activities, and that a failure to properly report any changes in that information using the CMS 855 form creates a risk of being subject to serious sanctions. Providers and suppliers should develop a clear understanding of what is legally required to complete the CMS 855 forms, use them to report changes appropriately, and obtain assistance as necessary in this regard to help assure compliance or deal with regulatory authorities. This will allow providers and suppliers to avoid delays in processing and initial activation, but more importantly to minimize the potential for deactivation of their Medicare number, revocation of billing privileges, further adverse consequences to the provider or supplier, or adverse consequences to other Medicare-enrolled entities having common ownership with the provider or supplier. n Health Care Compliance Association • 888-580-8373 • www.hcca-info.org September 2006 29
Page 1 and 2: Volume Eight Number Nine September
Page 3 and 4: ASK John asks the leadership your q
Page 5 and 6: the Health Care Compliance Associat
Page 7 and 8: Health Care Compliance Association
Page 11 and 12: You’re a compliance professional,
Page 13 and 14: A-110, or applicable regulation. n
Page 15 and 16: ogy, human resources, Erickson Adva
Page 19 and 20: is to make your hotel reservations
Page 21 and 22: September 2006 Health Care Complian
Page 25 and 26: those that have already enrolled in
Page 27: New Medicare enrollment regulations
Page 33 and 34: properly documented IRB or Privacy
Page 35 and 36: ment, on the theory that although d
Page 37 and 38: The Health Care Compliance Associat
Page 39 and 40: Register Today! Physician Practice
Page 41 and 42: They also are extremely credible an
Page 43 and 44: FYI ...continued from page 22 Sterr
Page 45 and 46: ■ William Munson, North Colorado
Page 47 and 48: ® SMART2.o : bringing HIM people a

JO - Health Care Compliance Association

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