On September 14, 2009, the Centers for Medicare & Medicaid Services (CMS) issued three new transmittals – Transmittals 556, 557, and 558 – regarding a limited provider revalidation effort. The three transmittals, dealing with the revalidation of Part B suppliers, individual Part B practitioners, and skilled nursing facilities (SNFs), rescind and replace transmittals previously issued on August 21, 2009. The previously released transmittal on revalidation of slide preparation facilities currently remains unchanged.

The revalidation effort will continue focus on the top fifty (50) billers, determined by dollar value of submitted claims, within each state in the above categories. The previous transmittals said that only those entities that do not have an established record in the Provider Enrollment, Chain and Ownership System (PECOS) or an Electronic Funds Transfer (EFT) agreement would be included in the revalidation effort. In the new transmittals, CMS has deleted what it called an erroneous reference to EFT in each of the three earlier transmittals. Its focus in selecting enrollees for revalidation is apparently now based solely on the absence of a PECOS record.

Generally, pursuant to the Federal Regulations found at 42 CFR 424.515, providers and suppliers are required to revalidate their enrollment information every five (5) years. The revalidations that are the subject of these transmittals are being conducted as off-cycle revalidations, in addition to the regular five (5) year revalidation cycle, pursuant to 42 CFR 424.515(d).

The Division of Provider and Supplier Enrollment (DPSE) expects that Medicare contractors will mail initial revalidation letters to the selected Part B suppliers and individual Part B practitioners by October 14, 2009, while the initial revalidation letters will be mailed to the selected SNFs on October 14, 2009. CMS notes that for SNFs, contractors responsible for multiple states may stagger the mailings at the rate of one state every thirty days, once implemented. CMS also notes that a SNFs' revalidation pursuant to these letters does not require a new state survey, and that SNFs that initially enrolled or that have been revalidated in the past five years will not be solicited at this time.

If you receive this letter from your contractor do not let it lie on your desk. The provider enrollment rules provide for revocation of Medicare enrollment for failure to return the completed form with documentation within sixty (60) calendar days. If this happens, you will not be able to bill Medicare until the problem is corrected.