The Centers for Medicare & Medicaid Services (“CMS”) provided additional details and information related to CMS provider enrollment site visits. On November 4, 2024, CMS issued a Quality and Safety Special Alert memo (“QSSAM”), “Clarification of CMS’ Provider Enrollment Visits (all providers and suppliers) and Specific Disclosure Requirements for SNFs and NFs.”
CMS provides some clarification for all providers, including nursing homes, hospices and home health agencies, on CMS provider enrollment site visits to Medicare-certified providers that are outside of the survey and certification oversight process.
The new CMS QSSAMs are memos focused on specific provider types and often serve as reminders of existing obligations or requirements. The QSSAM memos will not modify the existing survey and certification policies.
Site Verification Visits
CMS conducts a site visit verification process, separate from CMS or State Survey Agency health and safety surveys, for all provider types using National Site Visit Contractors (“NSVCs”). A site visit is intended to prevent questionable providers and suppliers from enrolling or staying enrolled in the Medicare Program.
The NSVCs conduct unannounced site visits for all Medicare Part A and B providers and suppliers. The NSVCs may conduct an observational site visit or a detailed review to verify enrollment-related information and collect other details based on pre-defined CMS checklists and procedures.
During an observational visit, the inspector has minimal contact with the provider and the visit should not hinder the provider’s daily activities. The inspector will take facility photos as part of the site visit. During a detailed review, the inspector enters the facility, speaks with staff and collects information to confirm the provider’s or supplier’s compliance with our standards.
Inspectors performing site visits will carry a photo identification and a CMS-issued, signed authorization letter that the provider or supplier may review. An inspector’s inability to perform a site visit may result in denial of the Medicare enrollment application or revocation of Medicare billing privileges.
Enrollment site visits are conducted by two NSVCs:
- East: Palmetto GBA and its subcontractors:
- Overland Solutions, Inc., an affiliate of EXL
- Information Discovery Services
- Compliance Review, Inc.
- National Creditors Connection, Inc.
- West: Deloitte Consulting, LLP and its subcontractors:
- Nationwide Management Services, Inc.
- CSI Companies, Inc.
- Arthur Lawrence Management, LLC
- Computer Evidence Specialists, LLC
CMS provided that the unannounced site visits are conducted during normal business hours (9 AM to 5 PM) or posted business hours. The visits include an external or internal review, by an inspector, with limited disruption to the operations and photographs of the business are taken.
Outcomes of Visits
Administrative actions could result if the listed CMS-855A Medicare Enrollment Application practice location address is: (1) a vacant suite with no signage and/or is posted for lease; (2) a practice location has signage, but no business activity is observed during posted hours of operation; or (3) an unrelated business is identified that does not match a listed “doing business as” name.
Several regulations address possible administrative action options.
- Under 42 CFR §424.535, CMS may revoke a currently enrolled provider’s or supplier’s Medicare enrollment and any corresponding provider agreement or supplier agreement for the following reasons, including: (1) noncompliance with enrollment requirements; (2) if upon on-site review CMS determines that the provider or supplier is no longer operational to furnish Medicare-covered items or services; and (3) the provider fails to report a change of information
- Under 42 CFR §424.540, CMS may deactivate Medicare billing privileges if the provider’s or supplier’s practice location is non-operational or otherwise invalid.
Practical Takeaways
- Ensure your office staff are aware of the site visit verification process.
- Providers may request to review the documents but cannot copy or retain them.
- To verify an inspector is associated with a CMS-ordered site visit, contact your Medicare Administrative Contractor.
If you have any questions or would like additional information about this topic, please contact:
- Sean Fahey at (317) 977-1472 or sfahey@hallrender.com;
- Brian Jent at (317) 977-1402 or bjent@hallrender.com;
- Todd Selby at (317) 977-1440 or tselby@hallrender.com; or
- Your primary Hall Render contact.
Hall Render blog posts and articles are intended for informational purposes only. For ethical reasons, Hall Render attorneys cannot—outside of an attorney-client relationship—answer specific questions that would be legal advice.
