I recently read CMS intends to separate its DMEPOS State Licensure Database oversight into a standalone agreement, this according to a recent meeting with National Provider Enrollment (NPE) contractors. The move could lead to a better resource for DME suppliers and a better enforcement tool for regulators.
Next Episode: Thursday, September 21, 2023
Investigating each states’ licensing requirements independently is difficult and inefficient. A unified resource is a dreamy concept, but the promise of the current database has been challenged with missing and obsolete data.
The reason?
CMS historically lumped responsibility for the licensure database in with the NPE predecessors, the National Supplier Clearinghouse (NSC). In the competition for NSC priority, compiling and updating new information from state licensing boards took a back seat to enrollment.
Better Accuracy. Increased Medicare Suspensions?
A separate contractor with a singular focus will likely result in more timely database updates as states add or modify their regulations. Suppliers may even – fingers crossed – receive advance notice of upcoming changes to licensing rules.
That focus, however, will almost certainly lead to more scrutiny. Licensure violations are grounds for immediate – and potentially retroactive – revocation of Medicare billing privileges. I don’t need to tell you what a cash flow nightmare the loss of a PTAN number can cause.
How to Avoid PTAN Revocations Related to State License Violations
If checking up on licensure requirements has not been at the top of your recent to-do list, I encourage you to make time now to confirm your ducks are in a row. If you find – and fix – errors before the contractor does, you may reduce the risk of a citation for non-compliance.
To start, visit the DMEPOS Licensure Database on the NPE West website:
- Select one of your linked PECOS states from the drop down box.
- Click the button “Export CSV.”
- Click the option for “Full or Partial Results.”
Do not use the option for “Disregard ‘No License Required.’” The feature has a known bug that exports blank results and may not be reliable.
The search results include all products and licensure requirements for suppliers both in and out of state. Simply filter the list by products linked to your PECOS application.
While the licensure database is a good place to start, the current version does have some accuracy issues, I strongly recommend you verify requirements with each state directly for the products your company offers per its PECOS Medicare application.
Take Immediate Action to Remedy Missing or Expired Licenses
Upon finding a licensure discrepancy, stop or hold all orders related to non-compliant products or service areas. Doing so is the critical first step.
For products or service areas no longer supplied, log into PECOS and remove those products and states. For active products and service areas, resume billing after securing the applicable licenses and uploading them to PECOS.
Changes are coming as CMS charges a new contractor with monitoring state requirements. Proactive measures now will prepare suppliers for intense scrutiny later.