CMS Clarifies Medicare Enrollment Application (855s) Bonding and Accreditation Deadlines for NCPA

Bonding Information


Pharmacies are required to have surety bond for each practice location unless the supplier is a sole proprietor by October 2, 2009.
If your pharmacy is enrolled as a DMEPOS supplier with the NSC and bills the DME MAC (formerly a DMERC) for non-accredited products, including Epoetin, immunosuppressive drugs, infusion drugs, nebulizer drugs, or oral anticancer drugs, you are required to have a surety bond. Note: The DMEPOS Surety Bond final rule did not establish an exception to the bonding requirement for pharmacies. Any supplier enrolled with the NSC is considered a DMEPOS supplier.
Accreditation Information
“Survey ready” DMEPOS suppliers (including pharmacies) who obtain facility accreditation and a surety bond after September 1, 2009 but before October 1, 2009, should submit proof of both to National Supplier Clearinghouse (NSC) via submission of an amendment to their CMS-855S (Medicare enrollment application).

Sections 1, 2, 12 and 15 (if you are the authorized official) or 16 (if you are a delegated official) should be completed and accompanying documents described in Section 17 should be provided. You will need proof of delivery, therefore it is suggested you mail the amended application and accompanying documents, to the overnight mailing address identified on page 2 of the application, certified mail, return receipt requested or use another verifiable package tracking system. Keep a copy of your amended CMS-855S in your files.

While pharmacies have until close of business September 30, 2009 to amend their CMS-855S, pharmacies are encouraged to update their Medicare enrollment application with the NSC as soon as possible.

Here are CMS answers to the most frequently asked questions by NCPA members regarding the accreditation and surety bond deadlines.

1. I’m “survey ready” but unlikely to be inspected prior to the October 1, 2009 (accreditation) deadline. I have obtained a surety bond. What are my options?

Answer – You have two options.

Option 1 – Amend your CMS-855S to furnish only drugs and biologicals (including Epoetin, immunosuppressive drugs, infusion drugs, nebulizer drugs, or oral anticancer drugs).

To amend the CMS-855S, complete sections 1, 2 and 12, 15 or 16, attach a copy of the surety bond, and mail the amended enrollment application to the NSC. Note: You do not have to complete the entire CMS-855S.

You can send the enrollment package to the NSC via overnight express. The NSC overnight express address can be found on page 2 of the CMS-855S. You will need proof of delivery, therefore it is suggested you mail the amended application and accompanying documents, certified mail, return receipt requested or use another verifiable package tracking system. Keep a copy of your amended CMS-855S in your files.

Option 2 – Voluntarily Withdraw/Terminate from the Medicare program.
You can voluntarily terminate your enrollment in the Medicare program by completing the sections associated with voluntary termination on page 4 of the CMS-855S. You can even notify the National Supplier Clearinghouse of a future date termination. After completing the applicable sections, the Authorized or Delegated Official should sign, date and mail the completed termination request to the NSC.
Note: If you voluntarily withdraw/terminate your enrollment with Medicare, you will be
required to re-enroll at future date to be eligible to participate in the Medicare program.
Thus, this option should only be considered by pharmacies who are not furnishing
drugs and biologicals (including Epoetin, immunosuppressive drugs, infusion drugs, nebulizer drugs, or oral anticancer drugs).


2. I received my facility accreditation certificate after October 1, 2009. Now what do I do?

Answer – Amend your 855S to add DMEPOS products back into your product offerings.

To amend the CMS-855S, complete sections 1, 2, 15 or 16, attach a copy of the accreditation certificate, and mail the amended enrollment application to the NSC. Note: You do not have to complete the entire CMS-855S.

You can send the enrollment package to the NSC via overnight express. The NSC overnight express address can be found on page 2 of the CMS-855S. You will need proof of delivery, therefore it is suggested you mail the amended application and accompanying documents, certified mail, return receipt requested or use another verifiable package tracking system. Keep a copy of your amended CMS-855S in your files.

While it may take up to 60 days for NSC to notify you that you can once again bill for DMEPOS, you can begin billing for claims retroactive to coincide with the date of facility accreditation.

3. Can I meet the October 1st deadline if I receive my facility accreditation certificate on the 28th of September? I have my surety bond.

Answer – Yes.

Complete sections 1, 2 and 12, 15 or 16, attach a copy of the surety bond and accreditation certificate, and mail the amended enrollment application to the NSC. Note: You do not have to complete the entire CMS-855S.

You can send the enrollment package to the NSC via overnight express. The NSC overnight express address can be found on page 2 of the CMS-855S. You will need proof of delivery, therefore it is suggested you mail the amended application and accompanying documents, certified mail, return receipt requested or use another verifiable package tracking system. Keep a copy of your amended CMS-855S in your files.

4. I received an NSC notice of revocation of my Medicare billing privileges; however I submitted my facility accreditation and surety bond certificates along with an amended CMS-855S PRIOR to October 1st 2009. What are my next steps?

Answer –

You should submit a corrective action plan within 30 days of the revocation date or an
administrative appeal within 60 days of the revocation date. If you should submit a copy
of the amended CMS-855S along with copies of the facility accreditation and surety bond
certificates.

Attach to the letter of revocation, the certificates along with the proof of delivery receipt
to the NSC prior to October 1, 2009. Again, you will need proof of delivery, therefore it
is suggested you mail the documents to the overnight mailing address identified on page
2 of the CMS-855S enrollment application (or other address as identified in the letter of
revocation), certified mail, return receipt requested or use another verifiable package tracking
system.