Time to Re-Up

Doctors who have been enrolled in Medicare before March 25 this year and have Medicare patients will have to revalidate their Medicare enrollment as part of the new healthcare reform law going into effect.  Doctors who must re-enroll will be notified by their administrative contractors.

The requirement is part of the health care reform law’s effort to combat fraud.  Section 6401(a) of the Patient Protection and Affordable Care Act mandates screening procedures under new criteria for physicians and other health care providers of Medicare and Medicaid beneficiaries as well as those who participate in the Children’s Health Insurance Program.  

Just as with initial credentialing applications for Medicare/Medicaid, contractors will evaluate the re-enrollment using the new criteria.  Contractors will be provided with a list of physicians and health care professionals who have had a prior adverse action, such as license revocation, felony conviction or exclusion from federal health care programs.  New enrollments and revalidations will be checked against this list and physicians on the list could draw higher levels of scrutiny.

The revalidation notification will continue through March 23, 2013.  Once the physician receives the revalidation notification is received, providers will be given sixty days to respond to the request.   However, no action will be required if a provider enrolled on or after March 25, 2011 because these providers’ applications are already subject to a stricter level of scrutiny.   “Failure to submit the enrollment forms as requested may result in the deactivation of your Medicare billing privileges,” CMS stated.


About Timothy Cornell
Timothy Cornell is of counsel at Perry, Krumsiek & Jack, where he co-chairs the litigation group and has a significant internet law, healthcare and litigation practice. Mr. Cornell graduated from the University of Chicago, where he studied philosophy. Before he became a lawyer, Mr. Cornell was a journalist at the Boston Herald, the Philadelphia Inquirer and other newspapers. An investigative story he wrote for the Tennessean in Nashville uncovered a series of radiation experiments done on poor pregnant women during the Cold War that led to a class action lawsuit and a $10 million settlement with Vanderbilt University. He then went to Cornell Law School, where he graduated cum laude from Cornell Law School in 2002, and was editor-in-chief of the Cornell International Law Journal. He has litigated a wide range of commercial, securities and antitrust cases. Working for the famed lawyer David Boies, Mr. Cornell litigated a whistleblower case against the pharmacy benefit manager Medco that resulted in a $166 million settlement and was recognized as The Case of the Month in the June 2006 issue of American Lawyer magazine. He also defended a major telecom against claims of securities fraud, and successfully sued Genzyme and other pharmaceutical manufacturers under IP, antitrust, securities and other causes of action. He was part of a team of Boies, Schiller & Flexner that sued Visa, MasterCard and the ten largest banks in the nation on behalf of American Express. The case resulted in a $4 billion settlement, the largest in antitrust history. Mr. Cornell focuses much of his practice on helping third party payors discover overcharges and reign in their spending on healthcare, while continuing to advise startups. He currently represents a large municipal health plan in its claims of consumer fraud against a major pharmacy benefit manager. He also represents a range of internet law clients and is a network lawyer for the Berkman Center for Internet & Society at Harvard Law School.

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