DMEPOS accreditation deadline extended to January 1
Next steps outlined for pharmacies as Congress considers permanent
fix as part of health care reform legislation.
In a win for pharmacy, President Obama signed the DMEPOS
Accreditation Extension Bill (HR 3663) on
October 13. The bill extends the deadline for accreditation of
pharmacies supplying durable medical equipment, prosthetics, orthotics,
and supplies (DMEPOS) to January 1, 2010, a delay from the previous
deadline of October 2.
Depending on what happens with health care reform (HCR) legislation,
the entire provision could be replaced with new—but currently
unknown—requirements. During the extension, APhA is providing
suggestions on what pharmacies should do based on informal discussions
with the Centers for Medicare & Medicaid Services (CMS).
The House of Representatives had passed a 90-day extension of the
deadline for pharmacies to obtain DMEPOS accreditation so that they can
be reimbursed for these supplies, but the Senate failed to act before
the October 2 deadline passed. That placed some pharmacies in jeopardy
for having their Medicare Part B billing privileges for DMEPOS suspended
by CMS. As
reported previously on pharmacist.com, CMS delayed its enforcement
actions in anticipation of Congressional action on this temporary
delay.
The Senate passed the bill without amendments under unanimous consent
on October 5. Stand-alone bills involving DMEPOS have been introduced
into Congress, but the most likely avenue for any further action is
inclusion of a permanent fix in a HCR bill.
APhA’s Government Affairs team—informed by discussions
with CMS—said that pharmacies, under certain circumstances, can
continue to bill Medicare for DMEPOS supplies. A pharmacy’s status
with the National Supplier Clearinghouse (NSC) will play a role in its
next steps:
- If a pharmacy already obtained accreditation and a surety bond, it
can continue to bill for Medicare Part B covered drugs and DMEPOS.
- If a pharmacy (1) did not seek accreditation, (2) plans to provide
only Part B drugs, (3) already submitted an updated CMS 855S form
to voluntarily remove itself as a DMEPOS supplier, and (4) has already
received confirmation from NSC of
their status change, the pharmacy cannot bill for DMEPOS. The pharmacy
must resubmit an updated CMS 855S form to opt back in to providing
DMEPOS supplies now that the extension has passed, as long as a surety
bond is in place.
- If, as in the previous scenario, the pharmacy submitted an updated
CMS 855S form but has not received confirmation from NSC of their status
change, NSC may not have processed the form. CMS has indicated that such
pharmacies can continue to bill for DMEPOS as long as a surety bond is
in place. CMS will not be enforcing the revocation of a pharmacy's
billing privileges. APhA encourages pharmacies to contact NSC to find
out that status of their application if they have not received
confirmation from NSC.
- If a pharmacy voluntarily terminated its DMEPOS enrollment prior to
the October deadline and acquires a surety bond in the future, an
updated CMS-855S form will need to be submitted to re-enroll in the
program.
- If a pharmacy did not voluntarily terminate its enrollment as a
DMEPOS supplier and/or did not secure a surety bond and had its billing
privileges revoked, the pharmacy is barred from re-enrolling in Medicare
for at least 1 year after the date of revocation.
As a reminder, regardless of accreditation status, October 2 was the
deadline for pharmacies to comply with the surety bond requirement in
order to continue to bill Medicare for Medicare Part B covered drugs
and/or DMEPOS supplies. For more information, read NSC's surety bond
FAQ.
Related resources on www.pharmacist.com
Related resources on the Web:
Beth Farnstrom, (bfarnstrom)
Posted October 22, 2009, 5:30 pm EDT
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