CMS Delays Part D Prescriber Medicare Enrollment Requirements until December 1, 2015
December 5, 2014 10:17 AM
As reported previously, as part of a final rule governing Medicare Advantage (MA) and Part D contracts for calendar year (CY) 2015, the Centers for Medicare & Medicaid Services (CMS) determined that, effective June 1, 2015, Part D plans may no longer cover drugs that are prescribed by physicians or other eligible professionals who are neither enrolled in Medicare nor have validly opted out of Medicare. In a recent MLN Matters article (SE143), CMS announced that this requirement will be delayed until December 1, 2015.
SE143 cautions that prescribers of Part D drugs must submit their Medicare enrollment applications or opt-out affidavits to their Medicare Administrative Contractors (MACs) by June 1, 2015 or earlier to ensure that the MACs have sufficient time to process the applications (CMS-855I) or opt-out affidavits (CMS-855O). This will avoid patients’ prescription drug claims from being denied by their Part D plans beginning with the deadline of December 1, 2015.
While many physicians that serve as hospice physicians are enrolled in Medicare, it is the understanding of the National Association for Home Care & Hospice (NAHC) that some hospice physicians are not. If these hospice physicians prescribe medications for Medicare beneficiaries that are unrelated to the hospice terminal illness or a related condition, and are appropriately covered under the patient’s Part D plan, it is advisable that these hospice physicians begin the process of either enrolling in Medicare in an approved status or of ensuring that they have a valid opt-out affidavit on file with an A/B Medicare Administrative Contractor (MAC). A valid National Provider Identifier (NPI) is required when filing the enrollment application or opt-out affidavit. CMS has an enrollment file available online that identifies physicians and eligible professionals who are enrolled in Medicare in an approved or opt out status.
Information on the general provider enrollment process and the time frames for application processing can be found on CMS’ web site here.