CMS has issued broad new regulatory requirements for provider enrollment and participation that will have significant, negative ramifications for all types of health care providers and suppliers enrolled in Medicare, any state Medicaid program, and the Children’s Health Insurance Program (CHIP), as well as possibly investors in the health care industry. Click here for the complete analysis by Reed Smith.

Specifically, in what CMS calls an effort to end “pay and chase” in federal health care programs, the Final Rule creates a new system of impracticable disclosure and monitoring obligations for newly enrolling and enrolled providers and suppliers and, at the same time, heightens CMS’ authority to deny or revoke enrollment status. This change comes with little due process or consideration for law-abiding enrollees.

Provisions include:

·     New and extensive affiliations disclosure and monitoring requirements

·     A broadening of CMS authority to revoke or deny enrollment

·     Increased and severe penalties for failure to comply with certain enrollment requirements.

Stakeholders characterized these proposals as misguided, unduly burdensome, and impracticable. CMS is seemingly dead-set on implementing these highly problematic provisions. Enrollees will generally be subject to the new requirements beginning November 4.

As always, ADVOCATE will keep you up to date on this and all issues impacting radiology as they become available.

Best regards,

Kirk Reinitz, CPA