Blog: The Healthcare Law Blog

Few surgery centers can remain economically viable without at least some level of government payor reimbursement. So imagine a scenario where the ASC’s Medicare or Medicaid receivables come to a screeching halt without warning; the enrollment has been deactivated. This does happen; sorting out why and how to fix it can take many months.

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Starting today, Department of Health Care Services (“DHCS”) is required to collect Medi-Cal enrollment fees of $505 per enrollment for “institutional providers.” DHCS Provider Enrollment Unit has issued no formal guidance regarding how it will implement the new requirements, and requests for information guidance from DHCS’ Acting Chief of Provider Enrollment have revealed few details regarding how a provider can comply with the new requirements.

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The Centers for Medicare & Medicaid Services (“CMS”) recently published proposed regulations that would implement provisions of the Patient Protection and Affordable Care Act as amended by the Health Care and Education Reconciliation Act of 2010 (collectively, the “Affordable Care Act”) relating to provider enrollment in Medicare, Medicaid and Children’s Health Insurance Program (“CHIP”). Published in the September 23, 2010 Federal Register, the proposed rules, if adopted, would introduce fingerprinting to the public-program enrollment process, expand provider-types subject to pre-enrollment and post-enrollment on-site agency review, specify details relating to the payment of fees for processing Medicare enrollment and revalidation applications, and provide new mechanisms for the establishment of Medicare and Medicaid enrollment moratoriums.

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