Medicare C & D Requirements to Terminate January 2019

by Billy Tarpley on November 29, 2017

Thanks to work by the ADA and congressional friends, the provisions that require dentists to enroll or opt-out of Medicare parts C and D will come to an end in January 2019.

As published in the ADA’s Legislative and Governmental Report on November 28:

On November 16, the Centers for Medicare & Medicaid Services (CMS) released a proposed rule titled, “Medicare Program: Contract Year 2019 Policy and Technical Changes to the Medicare Advantage, Medicare Cost Plan, Medicare Fee-for-Service, the Medicare Prescription Drug Benefit Programs, and the PACE Program”. This pre-inspection proposed rule will eliminate the current enrollment requirements for Medicare Part D prescription drugs and for Medicare Part C Medicare Advantage plans.

The ADA has been advocating to reform both of these duplicative paperwork requirements since introduced by CMS in 2014. Thanks in part to continued efforts of lawmakers including Rep. Kenny Marchant (R-TX) with his letter of support to HHS, and the introduction of a bill to change legislation that supports removing the Part D requirement for dentists — and other providers who are low prescribers and do not participate in Medicare. Rep. Drew Ferguson, D.M.D. (R-GA) and sixteen other Members of Congress also recently urged HHS to reconsider whether the regulation is burdensome and unnecessary for providers.

The proposed rule would also rescind the current provisions stating that providers must be enrolled in Medicare in order to provide health care items or services to a Medicare enrollee who receives his or her Medicare benefit through an MA organization. Instead, the new rule would require that the MA organization would not make payment for an item or service furnished by an individual or entity that is on the “preclusion list.”

Both the C and D rules include the “preclusion list” and verification of the National Provider Identifier (NPI) as requirements for either the pharmacy benefit manager or the Medicare Advantage plan. The proposed rule helps patients obtain care as more dentists will likely enroll in these insurance programs without the duplicate paperwork requirements and unnecessary compliance burdens. Dentists who are not otherwise required to enroll to submit a claim under Medicare will not have to enroll for these two purposes.

The proposed rule will be officially published on November 28th with the comment period until January 16th, 2018. It will take several months following the close of the comment period before the final rule is issued. Both rules are scheduled to take effect on January 1, 2019. CMS will very likely try to implement by mid-year 2018.

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