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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Health

Date & Time
  • event Date

    Wednesday, February 28, 2024

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

$297.00
CLE
ALL

This CLE webinar will guide practitioners through CMS' recent final updates to Medicare's provider and supplier enrollment regulations at 42 C.F.R. 424, Subpart P, that expand the scope of CMS' authority to revoke or deny enrollment in the Medicare program and contain other significant changes that create new and ongoing compliance obligations for providers and suppliers. The panel will also discuss the potentially harsh consequences of noncompliance and best practices to mitigate risk.

Faculty

Caroline Reignley
Partner
McDermott Will & Emery, LLP

Ms. Reignley provides strategic legal, regulatory and compliance counsel to for-profit and nonprofit hospitals, health systems, other healthcare providers, life sciences and technology companies. She counsels clients on interpretation and risk mitigation under the Anti-Kickback Statute, Stark Law and EKRA. She also advises on internal and government investigations related to the False Claims Act, Stark Law and Anti-Kickback Statue. Ms. Reignley advises clients involved in digital health on the applicable legal and regulatory infrastructure, with a particular focus on remote patient monitoring programs. She also advises Medicare providers, consultants and vendors on a wide range of business, legal and regulatory issues. She has extensive experience advising clients on Medicare and Medicaid fee-for-service reimbursement, billing and coding. She also advises clients on professional licensure, scope of practice, physician and health care professional clinician relationships and supervision, together with overall corporate compliance.

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Monica A. Wallace
Partner, Healthcare Regulatory & Compliance Practice Area Leader
McDermott Will & Emery, LLP

Ms. Wallace focuses her practice on complex regulatory and transactional counseling to healthcare organizations, including health systems, hospitals, ambulatory surgery centers, physician groups, dental providers, behavioral health clients, integrated delivery systems, academic medical centers, DMEPOS and pharmaceutical manufacturers and suppliers, home health agencies, and venture capital and private equity firms and their health-related portfolio companies. She concentrates her regulatory practice on healthcare fraud and abuse, Medicare and Medicaid enrollment, reimbursement and billing, legal assessments and audits, compliance programs, and other general regulatory matters including licensure, survey/certification and accreditation. Ms. Wallace’s transactional practice includes mergers, acquisitions and affiliations, divestitures, hospital/physician joint ventures and corporate reorganization.

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Grayson I. Dimick
Attorney
McDermott Will & Emery, LLP

Ms. Dimick provides strategic regulatory counseling for a wide variety of healthcare industry members. She delivers creative and practical legal solutions for digital health initiatives that comply with the constantly evolving regulatory landscape. Ms. Dimick counsels healthcare providers, health systems, private equity firms and their portfolio companies, and technology companies on regulatory, transactional and compliance matters. She advises on professional and facility licensure, corporate practice of medicine requirements, professional scope of practice and supervision, prescribing and reimbursement. She also assists clients with the development and implementation of telehealth programs.

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Description

The CMS recently finalized significant updates to Medicare's provider and supplier enrollment regulations at 42 C.F.R. 424, Subpart P, and related changes to Form CMS-855A as part of CMS' efforts to increase oversight of the Medicare program and to enhance program integrity and transparency. These changes affect new and existing Medicare providers and suppliers and create new and ongoing compliance obligations of which counsel should be aware given CMS' broad authority and the potentially harsh consequences for noncompliance.

Notable updates to the enrollment requirements include increasing the scope of CMS' authority to revoke or deny enrollment in the Medicare program; reducing the timeframe for reversing a revocation; and expanding the reapplication bar to 10 years for severe provider or supplier misconduct. The regulations also create a new "stay of enrollment" status, an interim status that may be imposed prior to any deactivation or revocation action, that allows for the provider or supplier to remain enrolled in Medicare.

Other changes include new and clarified definitions of certain provider enrollment concepts such as "indirect ownership interest" and "supplier," and new enrollment categories for marriage and family therapists and mental health counselors.

In addition to the changes in enrollment requirements, CMS has updated Form CMS-855A for the first time in 12 years with substantive and administrative updates.

Listen as our expert panel guides practitioners through the new CMS enrollment requirements for providers and suppliers. The panel will address notable updates in the enrollment regulations and changes to Form CMS-855A. The panel will also discuss consequences of noncompliance and provide best practices to mitigate risk.

Outline

  1. Introduction
  2. 42 C.F.R. 424, Subpart P updates
    1. Scope of CMS' denial and revocation authority over enrollment in the Medicare program
    2. Revocation effective date and timeframe to reverse a revocation
    3. Expansion of reapplication bar
    4. Change in practice location
    5. "Stay of enrollment" status
    6. New and revised definitions
    7. New mental health professional supplier types
    8. Other notable changes
  3. Form CMS-855A revisions
  4. Best practices for compliance

Benefits

The panel will review these and other important issues:

  • How do the updates expand CMS' Medicare enrollment denial and revocation authority?
  • What is the new "stay of enrollment" status and under what circumstances may it be imposed by CMS?
  • How has CMS broadened the circumstances under which a retroactive revocation date may be warranted?
  • What is the new timeframe for reversing a revocation?
  • How does the expanded reapplication bar affect providers and suppliers?
  • What are the potential consequences of noncompliance?