The Centers for Medicare & Medicaid Services (CMS) is reminding physicians that their practice’s “managing employees” must be listed on Medicare applications and that there could be dire consequences if they are not.
“You must report all current managing employees on your Medicare enrollment application, or we may deactivate your enrollment,” the agency advised in its MLN Connects newsletter in an item entitled “Medicare Providers & Suppliers: Report Managing Employees.”
The newsletter, which dispenses news from the Medicare Learning Network, noted that practices can make necessary updates by submitting an 855-enrollment application in Medicare Provider Enrollment, Chain, and Ownership System (PECOS) or by mailing a paper application to their Medicare Administrative Contractor or DME National Provider Enrollment Contractor.
Details on the requirement can be found in chapter 10 of the Medicare Program Integrity Manual, which says that a “managing employee means a general manager, business manager, administrator, director, or other individual who exercises operational or managerial control over, or who directly or indirectly conducts, the day-to-day operation of the provider or supplier, either under contract or through some other arrangement, whether or not the individual is a W-2 employee of the provider or supplier,” the manual says.
Other examples of managing employees listed by CMS include:
- Chief executive officer.
- Chief operating officer.
- Chief financial officer.
- Compliance officer.
- Regional manager.
- Clinical manager.
- Operations manager.
- Care coordination manager.
- Location manager.
- Administration manager.
- Compliance director.
- Clinical director.
Though this requirement is not new, the AMA and other physician organizations are working to spread awareness about it among their members.
“In many cases, it depends on the tenure of the managing employee or expertise of staff responsible for credentialing and PECOS,” said Anders Gilbert, senior vice president of government affairs for the Medical Group Management Association (MGMA).
Subscribe to free AMA email newsletters
Get the latest news from the AMA on the topics that matter to you—delivered to your inbox.
“Where we have found confusion at times is in situations where there has been administrative staff turnover,” Gilberg explained.
The managing employee-disclosure requirement is aimed at ensuring the integrity of the Medicare program, and Gilberg said he doesn’t see the new presidential administration removing it.
While this reporting requirement may not be that particularly onerous by itself, Gilberg noted that it is just one of many PECOS compliance issues that diverts physicians’ time and resources away from patient care.
Fix Medicare now
As part of its campaign to Fix Medicare Now, the AMA created the Medicare Basics series, which provides an in-depth look at important aspects of the Medicare physician payment system.
Learn how Medicare pay cuts:
- Endanger physician practices.
- Threaten patients’ access to care.
- Especially affect rural America.
- Hit solo physician practices hard.
- Put even big medical groups at risk.
Visit AMA Advocacy in Action to find out what’s at stake in reforming Medicare payment and other advocacy priorities the AMA is working on.
