How should MOA members respond to latest round of Palmetto/NSC revocation letters?

Some optometrists and ophthalmologists are receiving notices from Palmetto GBA, acting as the Medicare National Supplier Clearinghouse, revoking their DMEPOS billing number in 30 days for not having a surety bond. In response to AOA, the NSC acknowledged that they had no intent to revoke billing privileges from optometrists who are exempt from the surety bond requirement. After further discussions with CMS and NSC, we learned that in some cases the optometrist had checked "optician" on the 855s Medicare DMEPOS supplier enrollment form and, since opticians are not exempt, this has caused Palmetto to revoke the billing privileges.

Doctors who receive the notice of revocation should contact the NSC customer service line at 866.238.9652 to verify the Primary Specialty on file with the NSC. Unfortunately, the NSC customer service lines are very busy addressing multiple DMEPOS issues.

If the specialty type is incorrect, then the optometrist must respond to the Notice of Revocation letter by stating the intent to submit a Corrective Action Plan (CAP) or Reconsideration to the address provided in the letter. The doctor would submit the appropriate sections of the CMS 855s to change the primary specialty to the one that qualifies for the surety bond exemption (physician/optometrist). The supplier's CAP requesting such a change to the file should then qualify the physician supplier for the surety bond exemption if the practice meets Medicare requirement of only providing refractive lenses and contact lenses to their own patients. From the 855s, submit Sections 1A, 1B, 2B (Supplier Type), 3 and Section 15 (Authorized Official with original signature and date). The CAP must specifically state the intent of the supplier to submit a CAP or reconsideration.

If the specialty type is already correct and you received a notice of revocation, then you may want to contact the NSC and ask, specifically, what in your file caused them to send you that notice. You may also contact Rodney Peele at rpeele@aoa.org for further information or assistance.