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CMS Open Door Forum: Accreditation, Surety Bond, NCB Reminders

June 30, 2009 by Laurie Watanabe

The Centers for Medicare & Medicaid Services’ (CMS) Open Door Forum on June 30 consisted mostly of reminders for DMEPOS suppliers.

Among the topics repeatedly discussed: accreditation, national competitive bidding and surety bonds.

CMS’ Sandra Bastinelli, who presented the accreditation portion of the meeting/conference call, said she had five major reminders for DME suppliers:

— Make sure your enrollment application includes all of your business locations.

— Read the supplier standards and “also remember what they are.” For example: Only one DMEPOS supplier may do business at any one address; no co-habitating by suppliers at a single address is allowed.

— If you are choosing not to be accredited by Oct. 1, you cannot bill for any services/equipment provided after Oct. 1, regardless of when you actually submit the bill(s).

— If you do not comply by surety bond requirements and don’t voluntarily terminate your enrollment as a supplier billing Medicare for DME, your enrollment will be revoked. Please terminate your enrollment application yourself. If you do that, you can re-enroll at a later time, when you meet the requirements. But if you do not voluntarily terminate your application/enrollment and are revoked, you cannot re-apply for one year.

— DMEPOS subcontractors must be accredited unless they have professional exemptions.

Joel Kaiser, who led the national competitive bidding portion of the meeting for CMS, repeated that CMS expects to start the bidding process in fall 2009. In preparation, CMS is sending out weekly notices and intends to offer education on the nature of the competitive bidding program, how to register to participate, and how to submit bids.

Kaiser urged DME suppliers to update their files with the National Supplier Clearinghouse (NSC); make sure they have the required state licenses for various product categories, particularly if the supplier is new to the product category; and to get accredited.

“If you don’t start the process now, you’re really putting yourself in jeopardy” of not being able to participate in first-round bidding, Kaiser added.

CMS’ Frank Whelan reiterated that DME suppliers need to post surety bonds of $50,000 for each National Provider Identifier (NPI), i.e., each location. Whelan specifically mentioned a rumor he’d heard: that DME businesses with more than 20 locations need only post a surety bond of $1 million total. The rumor, he said, was not true: Each NPI/location needs a surety bond of $50,000, regardless of how many locations a DME business has in total.

A total of 440 participants were on the conference call, with the next Open Door Forum scheduled for July 29.

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