On September 10, 2019, the Centers for Medicare & Medicaid Services (CMS) issued a Final Rule addressing “Medicare, Medicaid, and Children’s Health Insurance Programs; Program Integrity Enhancements to the Provider Enrollment Process” (Final Rule).2 The Final Rule became effective November 4, 2019.3 It implements statutory requirements that providers and suppliers enrolling or already enrolled with Medicare, Medicaid and the Children’s Health Insurance Program (CHIP) disclose certain current and prior affiliations with other healthcare providers and suppliers with program integrity concerns. The Final Rule also expands CMS’s authority to deny or revoke a provider’s or supplier’s enrollment. CMS views its authority to grant, deny and revoke providers’ and suppliers’ enrollment as an essential program integrity tool to prevent against fraud, waste and abuse. In the Final Rule, CMS describes its expanded denial and revocation authority as necessary to enable “CMS to take action against unqualified and potentially fraudulent entities and individuals.”4 However, in addition to “unqualified and potentially fraudulent entities and individuals,” at times even well-meaning healthcare providers and suppliers have faced revocations for unknowing and unintentional lack of compliance with enrollment regulations. Given the high stakes for compliance outlined in the Final Rule, now, more than ever, it is essential for healthcare providers, suppliers and their legal counsel to familiarize themselves with the regulations to ensure compliance.
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