Health Care Reform Passes – What to do now if you are not accredited and "stepped down"
Pharmacies are exempt from DME accreditation requirements until January 2011. After that time, the new health care reform law requires that CMS provide an exemption from accreditation to pharmacies who Medicare DME billings average no greater than 5% of total pharmacy sales, have had a Medicare billing number in good standing for the last 5 years, and agree to provide certain documentation to prove they meet these criteria. A reading of the law would imply that pharmacies open fewer than 5 years and new pharmacies are not eligible for an exemption. Pharmacies that are currently accredited would not have to get reaccredited if they meet these criteria. We will be working with CMS to make sure that the new law is implemented consistent with Congress intent. Current law still requires DME suppliers to have a surety bond.
Some unaccredited pharmacies may have already stepped down from selling DME. Other may have voluntarily terminated. If you wish to now get back into the program, CMS has provided us with the following instructions:
1. Pharmacies that have “stepped down” MUST immediately amend their National Supplier Clearinghouse (NSC) Medicare Enrolment Application, 855s and “step up” (select the DMEPOS including diabetes supplies as described in 1C they wish to dispense). It may take up to 90 days for NSC to approve the amendments.
Complete Sections 1C, 2 (complete 2A1 and those data elements that are changing), 3, 13, and either 15 (if you are the authorized official) or 16 (if you are the delegated official), and 6 for the signer if that authorized or delegated official has not been established for this DMEPOS supplier.
2. If you have voluntarily terminated then you must complete all sections of the 855s. To activate once again may take longer than 90 days because the pharmacy must be re-inspected by the NSC to assure that the 25 NSC supplier standards are being met.
If you are reactivating your Medicare supplier billing number, complete all sections
3. Send in your 855s application registered mail or by other tracking carrier to the physical address below.
Overnight Mailing Address
National Supplier Clearinghouse
Palmetto, GBA* AG-495
2300 Springdale Drive, Bldg. 1
Camden, SC 29020
John M. Coster, Ph.D., R.Ph.
Senior Vice President, Government Affairs
National Community Pharmacists Association
100 Daingerfield Ave
Alexandria, VA 22314
703-683-8200 X184 - office
571-214-3936 - cell
john.coster@ncpanet.org
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