Successful Overturning of Medicare Revocation

We successfully defended a home-based practice in appealing a revocation of Medicare enrollment and billing privileges and associated three-year re-enrollment bar. The revocation decision alleged the practice was not operational during onsite surveys. To the contrary, the practice was fully operational at the address listed on the enrollment, where its administrative staff coordinated patient care, and its providers were also actively rendering clinical care to patients in their homes. CMS contractors are authorized to perform onsite surveys that enable it to verify that a provider actually exists and is providing the services it represented it would. In this instance, however, revocation of this operational practice would have resulted in the discharge of hundreds of patients with chronic and complex conditions, leaving most with gaps in care. The reconsideration-level appeal resulted in overturning the revocation and re-enrollment bar and reinstatement effective retroactively, allowing the client to avoid what is typically a multiple year and level appeals process.

We successfully defended a home-based practice in appealing a revocation of Medicare enrollment and billing privileges and associated three-year re-enrollment bar. The revocation decision alleged the practice was not operational during onsite surveys. To the contrary, the practice was fully operational at the address listed on the enrollment, where its administrative staff coordinated patient care, and its providers were also actively rendering clinical care to patients in their homes. CMS contractors are authorized to perform onsite surveys that enable it to verify that a provider actually exists and is providing the services it represented it would. In this instance, however, revocation of this operational practice would have resulted in the discharge of hundreds of patients with chronic and complex conditions, leaving most with gaps in care. The reconsideration-level appeal resulted in overturning the revocation and re-enrollment bar and reinstatement effective retroactively, allowing the client to avoid what is typically a multiple year and level appeals process.