AAPM&R Signs On to Letter to CMS on Proposed Rule on Program Integrity Enhancements to the Provider Enrollment Process

April 28, 2016

On April 21, 2016, AAPM&R, in a collaborative effort with the American Medical Association (AMA) and several other groups, signed on to a letter to the Centers for Medicare & Medicaid Services (CMS). This letter outlines recommendations in response to the Agency’s proposed rule (CMS-6058-P) implementing program integrity enhancements to the provider enrollment process for Medicare, Medicaid, and the Children’s Health Insurance Program (CHIP).

The Proposed Rule seeks to implement Section 6401 of the Affordable Care Act by requiring all reenrolling physicians to document any current or previous affiliation with a provider or supplier that has any of the following disclosable events:

1. Has uncollected debt;
2. Has been or is subject to a payment suspension under a federal health care program;
3. Has been excluded from Medicare, Medicaid or CHIP;
4. Has had its Medicare, Medicaid or CHIP billing privileges denied or revoked.

Medicare proposes to combine a 5-year look back period on the affiliations with an indefinite lookback period on the disclosable event. 

Your Academy supports this letter, as it addresses many concerns with the proposals, as well as the belief that the Agency’s regulatory impact analysis grossly underestimates the cost, in terms of lost patient care time, of completing a 5-year lookback on affiliations. 

Learn more about AAPM&R's advocacy efforts for the specialty of PM&R.