Affordable Care Act (ACA) Requirements
To become compliant with the Affordable Care Act (ACA)
requirements, the Indiana Health Coverage Programs (IHCP) has made
significant changes to provider enrollment policies and procedures.
ACA-related requirements are summarized below.
Ordering, Prescribing, or Referring Practitioners
For Medicaid to reimburse for services or medical supplies
resulting from a practitioner's order, prescription, or referral,
the Affordable Care Act requires that the ordering,
prescribing, or referring (OPR) practitioner be enrolled in
Medicaid. To address this new requirement and to encourage
nonenrolled practitioners to enroll in the IHCP, a new category of
enrollment has been created for OPR providers. Practitioners
already enrolled as IHCP providers do not need to do anything new.
Practitioners not otherwise enrolled as IHCP providers can enroll
as OPR providers. This new OPR provider category is appropriate for
practitioners who:
- May occasionally see an individual who is an IHCP member who
needs additional services or supplies that will be covered by the
Medicaid program; and
- Do not want to be enrolled as another IHCP provider type;
and
- Do not plan to submit claims to the IHCP for payment of
services rendered.
The OPR Provider Packet is a simplified application that asks
for minimal information from practitioners who only order,
prescribe, and refer IHCP members for services or supplies. The new
OPR Provider Packet is posted on the OPR
Providers page.
For practitioners who choose to enroll as OPR providers,
it is important to remember that an OPR provider cannot submit
claims to the IHCP for payment for services rendered. If the
practitioner wishes to be able to submit claims, enrollment as
another IHCP provider type is required.
Provider Revalidation
Under the Affordable Care Act (ACA), the Indiana Health Coverage
Programs (IHCP) is required to revalidate all provider enrollments.
The ACA screening criteria apply during revalidation.
Note: Revalidation requirements do not apply to
practitioners enrolling only as OPR Providers.
Providers will receive notification letters with instructions
for revalidating 90 and 60 days before their revalidation deadline.
Providers should not take any steps to revalidate until they
receive their notification letters. Providers that fail to submit
revalidation paperwork in a timely manner will be deactivated from
participation in the IHCP as of the deadline date.
Revalidation of enrollment will occur on a regular schedule.
Under the ACA, states are required to revalidate providers at
intervals not to exceed every five years. A more frequent
three-year revalidation requirement applies to durable medical
equipment (DME) and home medical equipment (HME) providers,
including pharmacy providers with DME or HME specialty enrollments.
Providers will be notified every three or five years when it is
time to revalidate their IHCP enrollments.
For more information, see Chapter
4 of the IHCP Provider Manual.
Note: Revalidation of enrollment is not the
same as recertification of enrollment credentials. See the
Recertify Provider Enrollment Licenses and Other Certifications
web page for details about the recertification process.
Application Fee
Certain providers are subject to an application fee. The
Provider Type Application Fee and Risk Assignment Matrix (for Non-Waiver and
Waiver providers)
provides a full list of provider types, and indicates which are
subject to the application fee. Generally, the application fee
applies to "institutional" providers, as defined by CMS, and not to
individual professionals, such as physicians.
Note: The application fee does not apply to
practitioners enrolling only as OPR Providers.
For those providers subject to an application fee, the fee is
assessed in full for each service location at initial
enrollment or with a change of ownership.
The application fee is NOT an annual assessment.
Please note: If a provider's service location
is enrolled in Medicare or the provider pays an application fee to
another state's Medicaid agency for a specific service location,
the provider is not required to pay an application fee for that
service location to the IHCP.
The Centers for Medicare & Medicaid Services (CMS) sets the
application fee amount, which may be adjusted annually. The
application fee amount for enrollments in 2012 is set at $523. The
application fee for enrollments received in 2013 is set at
$532.
Payment Options
The application fee can be paid using one of the following
electronic methods only. Paper forms of payment are not
accepted.
- Online - Go to the IHCP Bill Pay site
and follow the on-screen instructions. You can pay online using a
credit card, debit card, or electronic funds transfer from your
checking account. When the transaction is complete, you will be
given a confirmation number to enter in the appropriate section of
your IHCP Provider Packet.
- By Phone - Contact HP Customer Assistance at (317) 655-3240 in
the Indianapolis local area or toll-free at 1-800-577-1278 and
select the appropriate option. Please have your credit card, debit
card, or checking account information ready. When the transaction
is complete, you will be given a confirmation number to enter in
the appropriate section of your IHCP Provider Packet.
Providers can download HP's Federal W-9
form from this website for reporting payments on the provider's tax
forms.
In rare instances the CMS may agree to waive the application fee
based on proof it presents a financial hardship for a provider.
Providers requesting a waiver of the fee must submit a letter with
their enrollment packet. The letter must make a compelling case for
the request, including a description of the ways in which the
provider attempted to raise the funds. The final decision to waive
the fee is made by the CMS. If a CMS waiver of the application fee
was previously granted for the specific provider service location
with Medicare or another state's Medicaid program, a copy of the
waiver letter can be submitted with the IHCP Provider Packet as
proof of financial hardship.
Provider Risk Levels
Providers are categorized by risk level - high, moderate, or
limited. This determination is made by the Centers for Medicare
& Medicaid Services (CMS), based on an assessment of potential
for fraud, waste, and abuse for each provider type. The Provider
Type Application Fee and Risk Assignment Matrix (for Non-Waiver and
Waiver providers)
provides a full list of provider types and their CMS-assigned risk
levels, both for enrollment and revalidation. Please note that the
risk level assignment of an individual provider may be increased at
any time at the discretion of the State. In these instances, the
provider will be notified by the State, and the new risk level will
apply to processing enrollment-related transactions.
Providers enrolling, revalidating, or changing ownership will be
screened according to their assigned risk level. The following
table outlines the general screening activities required for each
risk category.
Note: Risk level assignments do not apply to
practitioners enrolling only as OPR Providers.
Risk Level
|
Screening Activities |
| High |
- Fingerprinting and criminal background check for all
individuals with ownership in the entity of 5% or more
(implementation pending)
- Unannounced site visits before and after
enrollment/revalidation
- Verification of provider-specific requirements, including but
not limited to the following:
- License verification
- National Provider Identifier (NPI) check
- Office of the Inspector General (OIG) exclusion check
- Ownership/controlling interest information verification
|
Moderate
|
- Unannounced site visits before and after
enrollment/revalidation
- Verification of provider-specific requirements, including but
not limited to the following:
- License verification
- NPI check
- OIG exclusion check
- Ownership/controlling interest information verification
|
| Limited |
- Verification of provider-specific requirements, including but
not limited to the following:
- License verification
- NPI check
- OIG exclusion check
- Ownership/controlling interest information verification
|
Fingerprinting and Criminal Background Check
Implementation Pending