Revenue Cycle

CMS Rural Health Open Door Forum Summary: October 18, 2011

Medicare Update for CAHs, November 16, 2011

Revalidation update

A CMS representative came on the line to give an update about the revalidation effort that is currently underway. The effort applies to those providers and suppliers that were enrolled in Medicare prior to the March 25, 2011 date, so newly-enrolled providers and suppliers that submitted their enrollment applications on or after March 25, 2011 are not affected by the effort.

The representative informed the audience that the easiest way to submit their revalidation is through the online PECOS system, and that there are a number of efforts underway for the online system and some of those changes are expected in late January, including a plan to implement an e-signature capability, which will eliminate the need for providers to submit their certification statement through the mail. CMS is also working on a “fast-track” tab which will give providers the ability to see all of their data that CMS has in the PECOS system and review it, and then submit back to CMS without having to fill out an entire 855 form.

Lastly, CMS reminded the audience that they are trying to manage the revalidation workload, and to avoid revalidating until you have received a notice from your contractor.

Advance diagnostic imaging program update

A CMS representative came on the line to remind the audience that anyone that bills Medicare and is reimbursed under the Physician Fee Schedule for the technical component of advanced diagnostic imaging requires accreditation effective January 1, 2012. The representative provided a few clarifications regarding accreditation:

  • If you are furnishing these services and billing Medicare, they must be accredited.
  • If you are providing the technical component by way of someone else (e.g. an accredited supplier that is a subcontractor but that accredited supplier is not billing Medicare,) you still need to be accredited.
  • If you have contracted all of your advance diagnostic imaging to another supplier who is accredited but that contractor is not billing on your behalf, meaning that you’re doing the billing because you are the one that is furnishing the services, you as a Medicare supplier still must be accredited. 

The representative reminded the audience that anyone who is not currently accredited or is in the process of accreditation will likely not be accredited in time for the January 1, 2012 deadline, as it takes on average, about three months to become accredited. Thus, if you wish to continue to bill for the technical component after January 1, 2012, contact one of the three CMS designated accreditation organizations by visiting The website contains an imaging accreditation tab that incudes all the contact information of the three accrediting organizations.. 

Comprehensive primary care demo

A CMS representative came on the line to inform the audience about a new initiative coming out of the CMS Innovation Center called the “Comprehensive Primary Care Initiative.” The program is a multi-payer initiative fostering collaboration between public and private healthcare payers to strengthen primary care for all Americans. The CPC initiative invites payers to join with Medicare in investing in primary care in 5-7 selected localities across the country, according to the website.

Outpatient therapy announcement

A CMS representative came on the line to remind the audience about the outpatient rehabilitation services project that is underway. CMS is currently recruiting providers particularly in rural areas in heavily rural states to participate by collecting assessment information on a series of their Medicare Part B therapy patients. The representative also informed the audience that CMS now has electronic data entry available for participants, which they believe will make things a lot easier for settings that choose to participate in the program. Providers can learn more about the project by looking at the project website at or contacting Ann Meadow at

Comments from Dr. Berwick and Q&A

Donald Berwick, MD, CMS administrator, joined the line at the end of the call, and after giving a brief introduction, spoke with a few callers on the state of rural healthcare in the country.

Dr. Berwick also answered a question for a caller that wanted to know what role rural health providers will play in the Medicare Shared Savings Program, and also, when he expected the final Accountable Care Organization rules to come out.

Dr. Berwick explained that by statute in the law in Section 3022, the ACO minimum number of patients is 5,000, but CMS has adjusted that for rural settings to a lower number, and that CMS is working to make the general idea of an ACO to be workable in rural settings. He also went on to state that the government intends for the Medicare Shared Savings Program to work and thrive in rural settings, and that CMS is keeping an eye on this situation.

A CMS representative reminded the audience that callers have the opportunity to build the agenda for future calls by emailing Carol Blackford at

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