Medicare enrollment procedures: Beginning this month, enrollment procedures for Medicare have changed. Risk levels have been assigned to provider types. DCs are considered the lowest risk level, or “limited” risk, to CMS.
The enrollment procedures that will be required for the limited-risk category will include SSN checks, licensing checks, NPI verification and other routine verifications. CMS is imposing a $505 application fee on certain providers, but DCs and other physicians will not be subject to the application fee.
E-prescribing: CMS has implemented a program to encourage providers to electronically prescribe medications. Doctors who are not electronically prescribing will have reimbursement penalties imposed beginning in 2012. There is a lot of misinformation regarding what a DC must do to avoid the payment adjustment.
To determine whether a doctor should be penalized for not e-prescribing, CMS’ first step will be to check the National Plan and Provider Enumeration System. If a provider is not an MD, DO, or podiatrist, nurse practitioner, or physician assistant as of June 30, 2011, based on the primary taxonomy code in NPPES, the doctor will not be subject to the payment penalty. No codes need to be reported if a doctor’s taxonomy code for his or her NPI record in the NPPES indicates the doctor is a “chiropractor.”
Medicare compliance programs: PPACA requires that Medicare providers have compliance programs in their offices. However, the legislation also indicates that CMS must provide specific guidance about what must be in the compliance program.
CMS has not yet released that guidance. However, once that information from CMS is available, ACA will provide a model compliance program for doctors. If doctors are attempting to meet the requirements of the law, it would be advisable to wait until further details are provided by CMS, rather than invest in procedures and products that may not meet CMS’ requirements.
Source: American Chiropractic Association, www.acatoday.org
