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New enrollment deactivation guidance provides ‘rebuttal rights’ to providers

An extensive manual change concerning enrollment deactivations suggests that CMS is trying to make it easier for providers to avoid the hassle of accidental removal from Medicare — but you still have to know and follow the rules.

Currently, Chapter 15 of the Medicare Program Integrity Manual, which covers enrollment, has simple templates for letters that providers will receive when they have been deactivated, with no discussion of how a provider or supplier might protest the decision. But look to Change Request 10978, which CMS issued Sept. 27, as the agency seeks to remedy this with rebuttal guidance. The updated policy guidance took effect Jan. 1, 2020.

The new versions brief providers on their “rebuttal rights.” Agencies will need to find critical details, such as filing format and deadlines, what to send, how to appoint a representative and more. For instance, “the rebuttal must state the issues or findings of fact with which you disagree and the reasons for disagreement,” according to the new transmittal.

Related links: View Change Request 10978 at https://go.cms.gov/35holIw. View the Medicare Program Integrity Manual, Chapter 15 at https://go.cms.gov/2YwGwqB.