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CLIENT ALERT: Medicare Providers having multiple locations should verify and revalidate their address information to avoid claim denials

MLN Matters SE19007 “Activation of Systematic Validation Edits for OPPS Providers with Multiple Service Locations” notifies providers that Medicare is now requiring the exact match of all addresses for practice locations that are listed on provider claim submissions to Medicare. (See attached)

Medicare began auditing in July 2018 for purposes of reinforcing Chapter 1, Section 170 of the Medicare Claims Processing Manual “Payments on the MPFS for Providers with Multiple Service Locations.”  The exact address match will be in full and effect once the July 2019 quarterly release is implemented.

Claims that do not have an exact address match will be returned to the provider.  Providers can make corrections to their service facility address for a claim submitted in the DDE MAP 171F screen for DDE submitters.

It is recommended that providers review their Medicare enrollment record and billing practices to ensure compliance with the exact address match requirement.  Medicare recommends that all providers update their billing records to match Medicare enrollment records.  Providers should verify and submit changes through the CMS-855A or CMS-855B application through the Provider Enrollment, Chain, and Ownership System (PECOS) as soon as possible.  Changes and updates to an address or the addition of a new location typically take Medicare 30–60 days to process.

If you would like copies of the regulations, need legal assistance with updating your Medicare enrollment information, or have any questions concerning these matters, please contact Amanda Waesch at 330-253-9185 or via email at alwaesch@bmdllc.com.

Vaccination Considerations for Employers

Today, three Covid-19 vaccines have tested as highly effective (90%+ efficacy) and are advancing in the process for emergency use. This is especially welcome news in Ohio, which has skyrocketing cases and our strategic response has been to turn the entire state into the small town of Bomont with strict curfews and bans on social gatherings.

Did You Receive More than $750,000 in Provider Relief Funds?

The Provider Relief Funds (“PRF”) - authorized under the CARES Act - has been a vital tool for health care providers during the COVID-19 public health emergency. These funds have allowed providers to stay open and continue to offer care during these pressing times. While helpful, these funds do come with several important obligations. First, fund recipients are required to comply with certain record-keeping requirements as well as comply with certain balance billing prohibitions. See our Client Alert. Second, fund recipients are required to report their intent, use of funds, and other data elements, which helps promote transparency to the federal government. Please see our Client Alert on provider relief fund reporting requirements. Third, and perhaps a new concept for many providers, fund recipients of more than $750,000 must undergo a “single audit” to ensure program compliance and appropriate use of funds.

Important Updates Every Provider Should Know: Information Blocking

In December 2016, Congress passed the 21st Century Cures Act (“Cures Act”) which: (1) authorized funding for the National Institutes of Health to promote medical research and drug development, (2) implemented provisions aimed at addressing the prevention and treatment of mental illness and substance abuse, and (3) reformed certain standards of the Medicare program and federal tax laws to foster healthcare access and quality improvement.

PPP Update: Loan Necessity Questionnaires

On October 26, 2020, the Small Business Administration (“SBA”) published a notice in the Federal Register which foreshadowed the release of two new forms seeking information from for-profit and nonprofit organizations that received Paycheck Protection Program (“PPP”) loans of $2 million or more. If approved, the SBA would use information from these forms to evaluate and determine whether economic uncertainty made a PPP loan request necessary.

Exposure to COVID-19 Flow Chart

Exposure to COVID-19 Flow Chart