Summary Of Covid-19 Medicare And Medicaid Provider Enrollment Waivers

Published: September 22, 2020


The Healthcare Law Blog

The Centers for Medicare and & Medicaid (“CMS”) have issued the following COVID-19 emergency blanket waivers for health care providers associated with provider enrollment.

To the extent applicable, the following screening requirements are waived:

  • Application fee.
  • Criminal background checks associated with fingerprint-based criminal background checks – 42 CFR §424.518.
  • Site visits – 42 CFR §424.517.
  • Postpone all revalidation actions.
  • Expedite any pending or new applications from providers.
  • Allow licensed providers to render services outside of their state of enrollment.
  • Allow physicians and other practitioners to render telehealth services from their home without reporting their home address on their Medicare enrollment while continuing to bill from their currently enrolled location.
  • Allow opted-out physicians and non-physician practitioners to terminate their opt-out status early and enroll in
  • Medicare to provide care to more patients.

Additionally, CMS has a toll-free hotline for physicians and non-physician practitioners and Part A certified providers and suppliers establishing isolation facilities to enroll and receive temporary Medicare billing privileges.

As to the Medi-Cal program, the California Department of Health Care Services has requested and received from CMS the following approved waivers under Section 1135 of the Social Security Act (the “Act”):

  • Authorization to provisionally, temporarily enroll providers who are enrolled with another State Medicaid Agency (“SMA”) or Medicare for the duration of the public health emergency.
  • With respect to providers not already enrolled with another SMA or Medicare, CMS will waive the following screening requirements under 1135(b)(1) and (b)(2) of the Act so California may provisionally, temporarily enroll the providers for the duration of the public health emergency:
  • Payment of the application fee – 42 C.F.R. §455.460.
  • Criminal background checks associated with Fingerprint-based Criminal Background Checks – 42 C.F.R. §455.434.
  • Site visits – 42 C.F.R. §455.432.
  • In-state/territory licensure requirements – 42 C.F.R. §455.412.
  • Temporarily cease revalidation of providers who are located in California or are otherwise directly impacted by the emergency.

These emergency blanket waivers as well as the approved waivers under Section 1135 are effective March 1, 2020 through the end of the public health emergency.