Washington -- Physician practices are anticipating major difficulties with Medicare enrollment rules that went into effect amid protests from doctors and practice managers. A wrong step by a practice could mean that it loses Medicare revenue or even gets kicked out of the program altogether.
Starting April 1, the time frame under which physicians can bill retroactively for services after successful enrollment or re-enrollment in Medicare has been shortened from 27 months to only 30 days. In addition, doctors must alert contractors of a change in practice location within 30 days, or risk expulsion from Medicare for up to two years.The policy changes appeared in the final 2009 Medicare physician fee schedule rule and were slated to go into effect Jan. 1. But the American Medical Association and the Medical Group Management Assn. convinced Centers for Medicare & Medicaid Services officials to hold off implementation while they discussed the organizations' concerns.
"Many of the changes to Medicare's enrollment process are cause for concern, and the AMA is working to improve the process so physicians can participate without disruption to their practice," said Board of Trustees Chair Joseph M. Heyman, MD.
Derise Woods, operations project manager for TeamHealth, an emergency department staffing services company based in Knoxville, Tenn., is particularly worried about the shortened retroactive billing period. Far from the flexibility of the old 27-month window, the new 30-day window is counted back from the filing date of an enrollment application that is subsequently approved.
"From a billing standpoint, this will have a great impact on our revenue," Woods said. Time is a precious commodity when it comes to providing medical services, particularly in an emergency department, she added. "You may have situations where providers will go to work before the paperwork can be provided to Medicare."
The AMA is still working with CMS to ensure that contractors are clear about the details of the new retroactive billing rule. Some potentially vague language in rule guidance has physicians concerned that not all practices will be allowed even a 30-day retroactive billing period.
Physicians who can't comply with the new retroactive billing timeline are at risk of losing payment for any services they billed before the 30-day limit. But doctors who fail to update their addresses within 30 days of moving face the potentially more costly penalty of being unable to bill the program at all for up to two years.