This is the first installment in a new series on the Physician Law Blog entitled “Small Doses” designed to provide you with quick updates on meaningful issues. We will continue to provide you with detailed updates on significant topics which we think are worth your time to read. The purpose of “Small Doses” is to give you just enough information regarding a topic to have a general understanding of its import in a quick, easy read.
CMS recently updated its list of reportable final adverse actions with respect to Medicare enrollment matters. The change became effective as of April 30, 2018. Going forward, suppliers (such as physicians, physician assistants and nurse practitioners) are no longer required to report prior revocations of their Medicare enrollment to CMS, and their medical practices are no longer required to report such revocations, including with respect to owners or managing employees of the practice.
Also, Medicare payment suspensions are no longer considered to be reportable final adverse actions on Medicare enrollment forms or the PECOS system.
CMS released a short, easy-to-read Medicare Learning Network article summarizing what final adverse actions must be reported on all Medicare enrollment forms and the PECOS system. The article is accessible at this link: MLN Article – Reporting Adverse Actions
Of note, CMS reminds all suppliers (such as physicians and their medical practices) that all final adverse actions (including those of owners and managing employees) must be reported to CMS through the applicable Medicare enrollment form or the PECOS system, regardless of whether the action (e.g., a felony or license suspension) has been expunged from a criminal record or is pending appeal in front of a court or agency.