Stay Ahead of changes in PECOS to avoid a “Stay of Enrollment” (i.e. Halted Payments!)
CMS has issued a change in regulation that may result a “Stay of Enrollment” which can halt all Medicare payments
The Essentials:
We want to bring your attention to a crucial regulatory change that will impact home health and hospice providers. CMS has issued a Change Request, number 13449, titled "Stay of Enrollment," which will result in the temporary hold of Medicare enrollment and zero payment of all claims if an agency failed to update their address, or apply for revalidation, upon the MAC request, until compliance is attained.
Please note that the Change Request is scheduled to take effect on May 30. However, some organizations have already experienced Stays of Enrollment in early May. This highlights the urgency for you to review and update your address information and promptly respond to any revalidation requests.
What does this mean for you?
It is essential to understand that a "Stay of Enrollment" can be triggered if you fail to promptly report a change of address or if you do not respond to a revalidation request. This new process is more sensitive and poses significant risks if not managed properly. It is important to remember that these are not the only two reasons that could lead to a Stay of Enrollment. Any changes requiring the filing of an 855 form to update your Medicare information might also trigger this status if not properly addressed.
Examples of non-compliance include (per the CMS Change Request):
An agency failed to timely report a change in its address from 10 Smith Street to 20 Smith Street
An agency didn’t respond to a revalidation request
An agency didn’t report the deletion of a managing employee
An agency didn’t timely report a change in their practice location’s ZIP code
Previously, deactivation of billing privileges could take a considerable amount of time to restore. However, this new Stay of Enrollment is a temporary hold that can be quickly reversed, which is a positive development.
Other facts about the “Stay” include:
You remain enrolled in Medicare during the stay
We’ll reject claims you submit with dates of service within the stay period
Your stay of enrollment lasts no longer than 60 days
We can impose a stay of less than 60 days
A stay ends on the earlier of the following dates:
The date on which we or your contractor decides you resume compliance with all Medicare enrollment requirements
The day after the imposed stay period expires
We may impose a stay multiple times for separate instances of non-compliance, for example, a stay in June 2024 and another stay in December 2025
A stay isn’t considered an adverse legal action of any kind
Nonetheless, it is crucial to ensure your address is current and that revalidation requests are responded to promptly to avoid any disruptions in Medicare payments.
We urge you to take this regulatory change seriously and ensure compliance to avoid any interruptions in Medicare payments. Stay proactive and stay informed!