BC Advantage - 2015 Issue 5
Important New Concerns for Billing Companies, Providers, and Suppliers
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Article Overview
This article explains recent CMS changes affecting Medicare enrollment and revocation of billing privileges for providers and suppliers. It covers the broader compliance and operational impact on billing companies, coding professionals, and healthcare organizations, including issues tied to ownership history, felony convictions, ambulance supplier billing, and patterns of improper claims activity. The discussion is aimed at readers who need a high-level understanding of the rule’s scope and the general types of precautions and planning considerations it raises.
Why This Topic Matters
The rule changes described can affect whether an organization can enroll in Medicare, keep billing privileges, or continue operating without interruption. Understanding the scope of CMS’s expanded authority helps billing and compliance teams recognize when Medicare enrollment, ownership changes, employee screening, and claim submission practices may require closer review.
Article Sections
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New Authority for CMS To Deny Medicare Enrollment and Revoke Billing Privileges
Introduces the CMS final rule and summarizes the major compliance areas affected across providers, suppliers, billing companies, and coding professionals.
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Denying Enrollment for Medicare Debts of a Prior Provider or Supplier
Discusses the expansion of CMS’s enrollment-denial authority in situations involving prior ownership, outstanding Medicare debt, and related risk considerations.
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Conviction of a Felony
Reviews CMS’s ability to act on felony convictions involving managing employees and the broader implications for screening and oversight.
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History of Felony Conviction
Covers CMS’s clarified authority concerning recent felony convictions involving providers, owners, and managing employees, along with related reporting concerns.
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Prohibition Against Back-Billing Medicare for Ambulance Suppliers
Explains changes affecting newly enrolling ambulance suppliers and the timing of Medicare billing for services.
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Revocation of Billing Privileges based on a Pattern or Practice of Billing Improper Claims
Addresses CMS’s expanded revocation authority for recurring claims issues and the general factors discussed in the article.
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Conclusion
Summarizes the article’s overall compliance message and the importance of addressing enrollment and billing-privilege risks.
What You Will Learn
- How CMS’s authority over Medicare enrollment and billing privileges has expanded
- Which broad compliance areas are affected by the final rule
- Why ownership history and prior Medicare debt can matter in enrollment decisions
- How felony-related issues involving owners or managing employees may affect Medicare participation
- What general change was made for ambulance supplier billing timing
- How recurring claim problems can raise revocation concerns under CMS review
Who Should Read This
- Billing companies
- Healthcare providers
- Medicare suppliers
- Coding professionals
- Compliance teams
- Healthcare attorneys
- Practice managers
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