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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.


HHS Revokes Public Comment Requirement on Certain Policy Changes

The U.S. Department of Health and Human Services (HHS) has revoked the Richardson Waiver, eliminating the requirement for public notice and comment on certain policy changes. This decision allows HHS to implement new policies more quickly, potentially affecting healthcare funding rules like Medicaid work requirements. While it speeds up policymaking, it also reduces opportunities for stakeholder input, raising concerns over transparency and unintended consequences for healthcare providers, states, and patients.

Don't Get Caught Dazed and Confused: Another Florida Court Weighs in on Employer Obligations to Accommodate Medical Marijuana Use

A Florida trial court ruled in Giambrone v. Hillsborough County that employers may need to accommodate off-duty medical marijuana use under the Florida Civil Rights Act (FCRA). This contrasts with prior rulings and raises new compliance challenges for employers. With the case on appeal, now is the time to review workplace drug policies.

Corporate Transparency Act to be Re-evaluated

Recent federal rulings have impacted the enforceability of the Corporate Transparency Act (CTA), which took effect on January 1, 2024. While reporting requirements were briefly reinstated, FinCEN has now paused enforcement and is reevaluating the CTA. Businesses are no longer required to submit reports until further guidance is issued. For updates and legal counsel, contact BMD Member Blake Gerney.

Ohio Recovery Housing Operators Beware: House Bill 58 Seeks to Make Major Changes

Ohio House Bill 58 proposes significant changes to recovery housing oversight, granting ADAMH Boards authority to inspect and investigate recovery residences. The bill also introduces a Certificate of Need (CON) program, requiring state approval for major facility changes. OMHAS will assess applications based on cost, quality, accessibility, and financial feasibility. The bill also establishes a recovery housing residence fund to support inspections. For more information, contact BMD attorneys Daphne Kackloudis or Jordan Burdick.

January 2025 Notice of Proposed Rulemaking Brings Notable Changes to HIPAA Security Rule

In January 2025, the U.S. Department of Health and Human Services proposed amendments to the HIPAA Security Rule, aiming to enhance cybersecurity for covered entities (CEs) and business associates (BAs). Key changes include mandatory compliance audits, workforce training, vulnerability scans, and risk assessments. Comments on the proposed rule are due by March 7, 2025.