HEALTH CARE Compliance & engagement Solutions

Since the start of the Centers for Medicare & Medicaid Services (CMS) Medicare Revalidation Process, Wilems Resource Group has recommended that ACOs utilize the Medicare Revalidation Website to monitor revalidation due dates and distribute reminders to ACO Participating Providers. This recommendation was based on the idea that ACOs have a need to ensure that Providers maintain their Medicare Enrollment status, and thus their eligibility to participate in the ACO.

CMS has recently confirmed that recommendation, stating on the January 8th “Medicare Shared Savings Program Kick-Off Webinar for the 2018 Performance Year” that ACOs have an obligation to ensure that Providers complete the Medicare Revalidation Process.  In an effort to understand the details around this obligation, Wilems Resource Group contacted CMS, their response consisted of three main points:

  1. The Shared Savings Program does not have the ability to monitor when providers have completed their Medicare Revalidation. 
  2. As an ACO, it is recommended that you obtain documentation of the ACO participant's successful revalidation, but it is not required.
  3. ACOs are required to report additions or deletions from their ACO Provider/Supplier List within 30 days of the change according to CFR 425.118(c). In so much as revalidation awareness would assist with this, the ACO should take that into consideration.

While CMS recommends that ACOs proactively obtain documentation of the successful revalidation, they acknowledge that this is not required.  Moreover, this is a large administrative burden for many ACOs and prohibitive for some.  Wilems Resource Group recommends the following steps be taken to encourage successful completion of the Medicare Revalidation Process:

  1. Ensure that Participation Agreements require Participants to notify the ACO if a provider or supplier is no longer Medicare enrolled. This will allow the ACO to update the Provider/Supplier List within 30 days of the change as required by CFR 425.118(c).
  2. Include a review of the Medicare Revalidation Webpage in your ACO’s Ongoing Monitoring Program. This will allow the ACO to provide notifications to providers when their revalidation date has been assigned.
  3. Provide notifications and instructional information to providers once their revalidation date is assigned via the Medicare Revalidation Webpage.  This notification should include information around the importance of completing the revalidation process as a requirement for continued participation in the ACO.

Medicare Revalidation Recommendation