CMS Dramatically Modifies and Expedites the Medicare Enrollment Process to Combat COVID-19

In response to the spread of Coronavirus (COVID-19), the Centers for Medicare and Medicaid Services (CMS) has waived certain Medicare and Medicaid program requirements under the authority granted to CMS by Section 1135 of the Social Security Act. This authority was triggered by the president’s declaration of a national emergency under the National Emergencies Act, and the Health and Human Services Secretary’s declaration of a public health emergency under the Public Health Service Act. For more information, see McDermott’s On the Subject “Section 1135 Waivers Now Available, But Some Waivers May Require Approval”.

Pursuant to its authority, CMS issued several “blanket” Section 1135 waivers that are available to providers and suppliers in relation to the COVID-19 pandemic. One such blanket waiver allows non-certified Part B physicians and non-physician practitioners to enroll and receive temporary Medicare billing privileges in order to increase the numbers of healthcare workers available to diagnose and treat patients with COVID-19. CMS waived the application fee, fingerprint-based criminal background checks, and site visits that are typically part of the screening requirements during the enrollment process. Through this waiver, CMS also postponed all revalidations and is allowing licensed providers to render services outside of their state of enrollment. Any pending or new applications will be processed on an expedited timeline.

The opportunity to temporarily enroll in Medicare Part B is extended only to physicians and non-physician practitioners. All other suppliers, including suppliers of durable medical equipment, prosthetics, orthotics and supplies (DMEPOS), are required to submit initial enrollments and changes of information via the appropriate CMS-855 application. Applications received on or after March 1, 2020, will be processed on an expedited timeline, and CMS has waived the application fee, criminal background checks and site visits for these applications.

Eligible physicians and non-physician practitioners seeking to temporarily enroll in Medicare Part B, either for the first time or at a new practice location, including a home address for services furnished remotely or via telehealth, can do so over the phone by contacting the Medicare Administrative Contractor (MAC) that is associated with their state of enrollment. To enroll, physicians or practitioners generally need the following information, depending on the provider/entity type:

Group MemberPhysician AssistantSole ProprietorOrganization

The MAC will attempt to screen and enroll the physician or non-physician practitioner over the phone, and will notify the physician or non-physician practitioner of approval or rejection of temporary Medicare billing privileges during the phone conversation. Applicants who are excluded from Medicare and other healthcare programs by the Office of Inspector General will be rejected. Applicants with a current adverse action on their license must wait at least 24 hours for CMS and the MAC to determine whether billing privileges will be granted. Approved applicants will receive a PTAN/billing number and a retroactive billing effective date that may be as early as March 1, 2020. The MAC will also send the provider a temporary billing approval letter.

Physicians and non-physician practitioners seeking to temporarily enroll in Medicare or to report a change in practice location pursuant to the Section 1135 waiver should contact their jurisdictional MAC at the phone numbers below, Monday through Friday. These hotlines should also be used by any physicians, practitioners or other suppliers who have questions regarding the other provider enrollment flexibilities afforded by the Section 1135 waiver. These hotlines will be operational until the public health emergency declaration is lifted.

The MACs will deactivate the temporary PTANs when the president declares that the national emergency is over. Providers seeking to fully enroll with the applicable MAC must submit a complete application, which the MAC will expedite.

Key Takeaways

Medicare will only make payments to providers and suppliers that are enrolled in Medicare Part B at the location where they provide services. In response to the challenges of providing care during the COVID-19 national emergency, CMS exercised its authority to allow temporary enrollment in Medicare Part B for certain categories of physicians and non-physician practitioners, and to expedite enrollment for other providers and suppliers. Individuals and entities seeking temporary enrollment, including of temporary practice locations such as a physician or non-physician practitioner’s home, should contact their MAC at the numbers listed above. Failure to seek temporary enrollment may result in rejected claims, delays in payment or inability to receive payment for services furnished to Medicare beneficiaries.