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

Client Alert

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.


The Ohio State University Launches Its Accelerated Bachelor of Science in Nursing Program

In response to Ohio’s nursing shortage, The Ohio State University College of Nursing is accepting applications for its new Accelerated Bachelor of Science in Nursing program (aBSN). Created for students with a bachelor’s degree in non-nursing fields, the aBSN allows such students to obtain their nursing degree within 18 months. All aBSN students will participate in high-quality coursework and gain valuable clinical experience. Upon completion of the program, graduates will be eligible to take the State Board, National Council of Licensure Exam for Registered Nursing (NCLEX-RN).

Another Transparency Obligation: The FinCEN Beneficial Ownership Information Reporting Requirements

Many physician practices and healthcare businesses are facing a new set of federal transparency requirements that require action now. The U.S. Department of Treasury Financial Crimes Enforcement Network (“FinCEN”) Beneficial Ownership Information Reporting Requirements (the “Rule”), which was promulgated pursuant to the 2021 bipartisan Corporate Transparency Act, is intended to help curb illegal finance and other impermissible activity in the United States.

“In for a Penny, in for a Pound” is No Longer the Case for Florida Lawyers

On April 1, 2024, newly adopted Rule 1.041 to the Florida Rules of Civil Procedures goes into effect which creates a procedure for an attorney to appear in a limited manner in civil proceedings.  Currently, when a Florida attorney appears in a civil proceeding, he or she is reasonable for handling all aspects of the case for their client.  This new rule authorizes an attorney to file a notice limiting the attorney’s appearance to particular proceedings or specified matters prior to any appearance before the court.  For example, an attorney can now appear for the limited purpose of filing and arguing a motion to dismiss.  Once the motion to dismiss is heard by the court, the attorney may file a notice of termination of limited appearance and will have no further obligations in the case.

Enhancing Privacy Protections for Substance Use Disorder Patient Records

On February 8, 2024, the U.S. Department of Health and Human Services (“HHS”) finalized updated rules to 42 CFR Part 2 (“Part 2”) for the protection of Substance Use Disorder (“SUD”) patient records. The updated rules reflect the requirement that the Part 2 rules be more closely aligned with the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) privacy, breach notification, and enforcement rules as mandated by the Coronavirus Aid, Relief, and Economic Security Act of 2020.

Columbus, Ohio Ordinance Prohibits Employers from Inquiries into an Applicant’s Salary History

Effective March 1, 2024, Columbus employers are prohibited from inquiring into an applicant’s salary history. Specifically, the ordinance provides that it is an unlawful discriminatory practice to: