Elizabeth Hogue Educates Us About Fingerprints

It seems as though some of you might be fingerprinted in the near future.   Elizabeth Hogue did such a good job of explaining it last week, we thought we would repost her email.  Elizabeth can be reached at:

(877) 871-4062
ElizabethHogue@ElizabethHogue.net

CMS Begins Fingerprinting “High Risk” Medicare Providers and Suppliers

The Centers for Medicare and Medicaid Services (CMS) issued MLN Matters Number SE1417 on April 11, 2014. This Special Edition MLN Matters is intended for providers and suppliers who submit claims to Durable Medical Equipment (DME) Medicare Administrative Contractors (MACs) and Home Health and Hospice MACs for services provided to Medicare beneficiaries. CMS makes it clear in this article that it will begin fingerprinting all owners of these types of providers with a 5% or greater ownership interest. The ultimate goal is to fingerprint all owners with a 5% or greater ownership interest in all providers or suppliers in the high risk category that receive reimbursements from the Medicare Program. According to CMS, the implementation of fingerprint-based background checks as part of enhanced enrollment screening of providers is based on Section 640 of the Affordable Care Act (ACA).

When fully implemented, the fingerprint-based background check will be required for all individuals with a 5% or greater ownership interest in a provider or supplier that falls under the high risk category. The high level of risk category applies to all providers and suppliers who are newly enrolling DME suppliers or home health agencies. This category will also apply to providers and suppliers who are elevated to the high risk category in accordance with enrollment screening regulations.

Fingerprint-based background checks will be implemented beginning in 2014. Providers and suppliers subject to fingerprinting will receive notification of the requirements from their MAC. The MACs will send notification letters to providers and suppliers that include a list of all owners with a 5% or greater ownership interest who are required to be fingerprinted. Letters will be mailed to providers’ or suppliers’ correspondence addresses and special payments addresses on file with Medicare. Individual fingerprinting will normally be required only once, but CMS reserves the right to request additional fingerprints, if needed. Owners will have thirty days from the date of notification letters to be fingerprinted. Providers and suppliers that find discrepancies in the list of owners sent to them by the MACs should communicate the discrepancies and take appropriate action to update enrollment records to reflect corrected ownership information.

Notification letters will include contact information for the Fingerprint-Based Background Check Contractor (FBBC). Individuals required to be fingerprinted are required to contact the FBBC prior to being fingerprinted to ensure that fingerprints are accurately submitted to the Federal Bureau of Investigation (FBI) and that the results are properly transmitted to CMS. Providers and suppliers subject to fingerprinting will be able to contact the FBBC by telephone or by accessing the FBBC’s website. Contact information for the FBBC will be included in notification letters sent by the MACs. The FBBC will provide at least three locations convenient to individuals’ locations where they can be fingerprinted. One of the locations must be a local, state, or federal law enforcement facility.

Individuals required to be fingerprinted must bear all expenses related to being fingerprinted.

CMS encourages providers and suppliers to provide fingerprints electronically, but CMS will accept the FD-258 card instead. FD-258 cards submitted will be converted to electronic submissions to the FBI by the FBBC.

Fingerprints will be sent to the FBI for processing. The FBI will compile background history based on fingerprints within twenty-four hours of receipt and will share the results with the FBBC. The FBBC will review each record and make recommendations to CMS regarding fitness. CMS will assess recommendations from FBBC and make final determinations. CMS may deny enrollment applications or revoke existing Medicare billing privileges based on its final determinations of the results of fingerprint background checks.

Providers and suppliers regularly face a number of hurdles in the enrollment process. The above addition to the process is bound to increase providers’ frustration. Meticulous compliance will be the name of the game!

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