Provider Enrollment: Reminder for Open Enrollment and Participation Agreement
The 2025 Annual Participation Open Enrollment Period is approaching for another year. While this is an important time (from mid-November to December 31) for providers to determine if they will become and/or remain participating for the upcoming year, we want to bring some reminders to your attention based on issues we have seen in the past.
The CMS-460 is NOT needed during open enrollment if the:
- Provider reassigns all Medicare benefits
- Provider is already participating and will remain participating
- Nonphysician practitioner is considered mandatory participation
CMS regulations in the CMS Internet-Only Manual (IOM) Publication 100-08, Medicare Program Integrity Manual, Chapter 10, Section 10.3.3.2 state:
- Individual physicians and nonphysician practitioners who only reassign benefits to a clinic/group practice inherit the participating status established by the clinic/group practice; accordingly, these physicians and nonphysician practitioners need not submit the Form CMS-460.
CMS regulations in the CMS IOM Publication 100-08, Medicare Program Integrity Manual, Chapter 10, Section 10.6.11 state:
- Nonphysician practitioners that are considered mandatory participation and individual physicians and nonphysician practitioners that reassign all of their benefits to a participating organization should not be entered as "PAR" in PECOS.
National Government Services receives and returns a great number of unnecessary CMS-460 Participation Agreements every year due to the regulations indicated above. Also refer to article: Participating Status on Provider Enrollment Approval Letters for more information about the participation status on approval letters.
Please review and share this information with all enrollment professionals within your organization.
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Posted 12/2/2024