All agencies must participate in the revalidation process. This requirement has been updated by the Change Request (CR) 9011 that was recently issued with an effective date of 05/15/15. This CR updates the Medicare Program Integrity Manual (PIM) on policies related to provider and supplier revalidations. Sections 15.29.1-15.29.10 of the PIM are new and include policies that outline the process and timing for revalidations and subsequent deactivations.

The revised policy includes that CMS will request that providers respond to a revalidation request within 60 days of sending the revalidation letter. If 60 days passes without response, the contractor is to contact the provider between days 60-70. The contractor is to make two attempts to contact the provider by phone. The call not being answered does not count as a contact. However, the contractor may leave a voice message if a phone number is left for a contact.

The provider will be place in a “pend” status if there is no response to the revalidation request by days 71-75. The contractor informs the provider of the “pend” status via phone or mail. The contractor may determine the method of notification. A letter will be sent if no other form of communication is working. While a provider will not receive any payments or remittance reports while in a “pend” status, this action in not applied to the shared systems. Therefore, providers will be able to order or refer services for Medicare beneficiaries. Home care agencies that accept orders from physicians while in this “pend” status will be able to bill Medicare and receive payment for services.

If revalidation response is received more than 120 days after deactivation, a new PTAN and effective date will be issued. The time between the end date of the old PTAN and the issuance of a new PTAN will be reflected as a gap in the provider’s enrollment record. In the CR, CMS states that the contractor shall not require any provider/supplier with billing privileges that have been deactivated to obtain a new State survey or accreditation as a condition of revalidation. Home Care Agencies would not be required to obtain a State survey or accreditation by an approved accreditation organization if they had been deactivated related to CMS’ revalidation policies.

CMS posted on their web site a list of all providers and suppliers who are currently enrolled in the Medicare (ordering and referring list). The site also contains a list of physician and non-physician providers who have an initial application pending. In addition, the site contains a list of providers and suppliers that been sent revalidation letters and a list of providers and suppliers that will be sent revalidation letters within the next 60 days.

The CR provides information on CMS’ policies related to the process and response timelines for revalidations when additional information has been requested by the contractor. The model letters contractors send to providers to request a revalidation and associated correspondence have been revised.

The CR can be found at the following link: CMS Manual System