Brace For The Transition — Enrollment Tips; CMS Changes California Mac Award Contract From Palmetto GBA To Noridian

The Centers for Medicare & Medicaid Services (“CMS”) recently announced that it awarded Noridian Administrative Services the contract for administration of Medicare Part A and Part B fee-for-service claims for California, Nevada, Hawaii and the American territories of American Samoa, Guam and the Northern Mariana Islands. Noridian will also take over additional Medicare operational functions, including provider enrollment functions. According to CMS, the workload transfer is to be complete by early 2013. However, if Palmetto GBA protests the bid award, this could significantly delay implementation.

The region to which the Medicare Administrative Contractor (“MAC”) award applies was previously referred to by CMS as “Jurisdiction 1,” but has been redesignated as Jurisdiction E.” Noridian currently is the MAC for “Jurisdiction F” which is comprised of Alaska, Arizona, Idaho, Montana, North Dakota, Oregon, South Dakota, Utah, Washington and Wyoming and, for Part A, Minnesota.

The current MAC for Jurisdiction 1/E is Palmetto GBA. While CMS indicates that it “anticipates that implementation of the new contract will go smoothly with few, if any, disruptions in service for Medicare beneficiaries and providers,” California providers may be trepidatious about the change based upon prior experience. Palmetto GBA assumed MAC responsibilities in 2008 from the prior National Heritage Insurance Company (Part B) (“NHIC”) and United Government Services, LLC (Part A).

During the 2008 transition, staff of both NHIC and Palmetto GBA confirmed that approximately one month prior to transition, NHIC simply boxed enrollment applications without any additional action and sent them to Palmetto. Palmetto staff indicated that they could not open and work those applications until their CMS contract began. Pending enrollment matters were held for several months. Palmetto phone lines were flooded with calls during the first months of the transition and Palmetto did not have sufficient phone lines or staff to receive incoming calls during the early months of the transition. These issues eventually cleared, but enrollment matters were essentially at a standstill for many months.

Providers can prepare themselves for this change by doing the following:

  1. Be alert to the transition and watch for future communications from CMS about the transition date and updates to the addresses for sending enrollment correspondence.
  2. Try to avoid having pending enrollment matters at the time of the transition of the MAC. If possible, accelerate or delay filing enrollment applications if possible and the business transactions that necessitate them.
  3. Be aware that the risk of MAC error in enrollment matters is likely to go up during the time of transition. Note that the timelines for requests for reconsideration of negative enrollment determinations are a mere 60 days; be prepared to file without delay if there are good grounds for doing so. Maintaining complete documentation relating to filed enrollment applications is as important as ever (including proof of delivery of filed documentation).
  4. Anticipate negative consequences on Medicare cash flow and prepare accordingly. In addition to the delays caused by changes in claims administration, increasing the time for processing enrollment applications is frequently accompanied by additional delays in securing the first Medicare payments for new businesses or those that have engaged in change of control transactions.