New Rebuttal Process for Medicare Providers
CMS has developed a new rebuttal process for providers whose Medicare enrollments have been deactivated. This new process begins on December 31, 2019, and gives providers the right to file a rebuttal to challenge their deactivation. Providers are given this opportunity to demonstrate that they meet all applicable enrollment requirements and their Medicare billing privileges should not have been deactivated.
Only enrollments that are deactivated for the following reasons can be challenged through the new rebuttal process:
- Deactivation because the provider or supplier did not submit Medicare claims for twelve consecutive calendar months.
- Deactivation because the provider or supplier did not report a change of information within 90 calendar days of when the change occurred or within 30 days if it is an ownership change.
- Deactivation because they did not respond to a revalidation request letter or to a request for corrections on a revalidation application.
- Deactivation because the provider is in an approved status but doesn't have any practice location or active reassignment for 90 calendar days.
Submitting a Rebuttal
All rebuttals must be submitted within 20 calendar days from the date of the deactivation notice. These requests can be mailed, emailed, or faxed to Noridian. Any rebuttal submitted after the 20 calendar days will be dismissed.
Noridian is currently working on a coversheet providers should include with their rebuttal. This coversheet will be located on the Noridian Medicare website when finalized. Along with this coversheet, providers should include specific reasons for the rebuttal as well as all supporting documentation that supports the rebuttal reason.
Rebuttals need to be signed by the individual provider, an authorized or delegated official on file or a legal representative. If the rebuttal submission is signed by an attorney, the attorney must also submit proof that they have the authority to represent the provider/supplier. If the correct signature is not sent with the rebuttal, we will be sending a request for that information. This and any other missing information that is requested must be received with 30 days of the request or the rebuttal will be dismissed. If we ask for a missing signature statement or appointment statement, the information must be received in 15 days.
Last Updated Dec 16, 2019