Compliance Corner

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Compliance Corner are now eligible to earn two CE credits. After reading this column, simply scan the QR code or use the link on page 33 to take the Compliance Corner quiz. Receive a score of at least 80 percent, and AOPA will transmit the information to the certifying boards.

THE NATIONAL SUPPLIER CLEARINGHOUSE (NSC) is the single organizational entity responsible for issuing or revoking Medicare supplier billing privileges for suppliers of durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS). The COVID-19 public health emergency (PHE) continues to affect many aspects of enrollment. By sharing information, NSC hopes to make the enrollment process easier for everyone.

Due to the current pandemic PHE, the following waivers are in place regarding Medicare suppliers who are currently, or are in the process of enrolling as, DMEPOS suppliers: • Supplier Standard 9: Business phone, maintains a primary business telephone that is operating at the appropriate site listed under the name of the business locally or toll-free for beneficiaries. • Supplier Standard 30: Minimum hours of operation, except as specified in paragraph (c)(30)(ii) of this section, is open to the public a minimum of 30 hours per week.

In addition, NSC is resuming normal site visit activity; therefore, any enrollment application received will not be finalized until a site visit is conducted. Revalidations also have been suspended. Visit the CMS website and view the “Current Emergencies” page for more information.

On Nov. 23, 2020, CMS issued a notice regarding the “Provider Enrollment Application Fee Amount for Calendar Year (CY) 2021.” Effective January 1, the CY 2021 application fee is $599 for institutional providers that are: 1. Initially enrolling in the Medicare or

Medicaid program or the Children’s

Health Insurance Program (CHIP). 2. Revalidating their Medicare,

Medicaid, or CHIP enrollment. 3. Adding a new Medicare practice location.

This fee is required with any enrollment application submitted from Jan. 1 through Dec. 31, 2021. (Note: As of Feb. 1, 2021, due to the COVID-19 PHE, enrollment fees will continue to be waived.)

Bonds are required to obtain or maintain Medicare billing privileges, per a CMS directive on Dec. 29, 2008. A DMEPOS surety bond is a bond issued by an entity (the surety) guaranteeing that a DMEPOS supplier will fulfill an obligation or series of obligations to a third party (the Medicare program). If the obligation is not met, the third party will recover its losses via the bond.

Surety bonds are required whether the DMEPOS supplier is nonparticipating or participating. With that being said, there are certain suppliers that may qualify for exemption. The exemption requirement can be found in its entirety in 42 CFR 424.57(d)(15).

Here are some applicable exemptions for suppliers that deal with orthotic and prosthetic services:

“State-licensed orthotic and prosthetic personnel in private practice making custom-made orthotics and prosthetics are exempted from the surety bond requirement if: (1) the business is solely owned and operated by the orthotic and prosthetic personnel, and (2) the business is only billing for orthotics, prosthetics, and supplies.”

Supplier Standard 1 mandates that “if a state requires licensure to furnish certain items or services, a DMEPOS supplier must be licensed to provide the item or service.” NSC provides a Licensure Directory, available at www.palmettogba.com/licensure/licdirec. nsf/NSCLicensureMap_N, to assist suppliers with changes and updates; however, this directory is meant only as a guide. It is the responsibility of the supplier to ensure compliance with state licensure requirements. Additionally, suppliers may utilize the NSC Web Form Submission option to submit licenses.

NSC offers the NSC Web Form Submission option at www4.palmettogba.com/NSC_WebForm_Submission/. This tool allows suppliers to respond to requests from NSC by uploading required documents. Items that can be uploaded include appeals, certificates of insurance, licenses, National Provider Identifier letters, responses to Supplier Audit and Compliance Unit requests, and surety bonds; in addition, suppliers will be able to respond to the Competitive Bidding Implementation Contractor (CBIC) preliminary bid evaluation directly from the web form tool.

Accessing the online NSC Web Form Submission tool reduces mailing time and alleviates the paper burden associated with submitting required documents. This tool does not allow for CMS-855S applications or any changes to information, and you may only submit documentation if you have a DMEPOS Provider Transaction Access Number (active or revoked).

Browse the NSC website at www. palmettogba.com/palmetto/nsc.nsf for additional information, and sign up for listservs at www.palmettogba.com/ home.nsf/emaillobselect to get the most up-to-date information delivered straight to your inbox. Finally, if you have additional questions regarding enrollment, you can email NSC directly at medicare.nsc@palmettogba.com.

EDITOR’S NOTE: All of the information provided in this article was current as of April 2021.

Malisa Rogan is the senior provider relations representative at National Supplier Clearinghouse.

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