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March 09, 2021

Collateral Consequences of Medicare Revocations

This Briefing is brought to you by AHLA’s Regulation, Accreditation, and Payment Practice Group.
  • March 09, 2021
  • Alison Hollender , Husch Blackwell LLP
  • Mackenzie Wortley , Husch Blackwell LLP

The Centers for Medicare & Medicaid Services (CMS) has the ability to revoke a provider’s Medicare Provider Agreement for failure to meet Medicare requirements. When revocation occurs, CMS terminates the provider’s Medicare Provider Agreement, including the provider’s Medicare billing privileges, and issues a reenrollment bar to prohibit the provider from enrolling in Medicare for a certain number of years. Even providers who do not treat many Medicare patients may be impacted by Medicare revocation since non-governmental payers often rely on Medicare certification to credential providers, Medicare revocation is reportable to the National Practitioner Databank (NPDB), and Medicare revocation may impact a provider’s future opportunities to work with Medicare providers.

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