April 29, 2016

ACR Urges Program Intensity Enhancements Rule Changes

The American College of Radiology recently told the Centers for Medicare and Medicaid Services (CMS) that parts of the Proposed Rule on Program Intensity Enhancements to the Provider Enrollment Process place undue burdens on physicians.

Among the many changes included in this rule, CMS would require providers who are submitting or revalidating their Medicare Provider/Supplier Enrollment Application (CMS-855) to disclose any and all relationships between owning or managing employees and current or previous providers who have or have had uncollected debt to Medicare or Medicaid or CHIP, have been subject to a payment suspension under a federal health plan, have been excluded from participating in Medicare, Medicaid, or CHIP, or have had their Medicare, Medicaid or CHIP enrollment denied, revoked, or terminated for any reason.

The ACR offered support for efforts by the Centers for Medicare & Medicaid Services (CMS) to preclude unqualified or potentially fraudulent individuals or entities from participating in applicable programs but took issue with many provisions. Among those proposed changes, are “look-back” periods of five years for previous affiliations, a new definition for “uncollected debt” and a “reasonableness” test for reporting disclosable events based on a “knew or should reasonably have known” standard.

Click here to read the full ACR comment letter to CMS.