CMS Clarifies Medicare Enrollment Application (855s) Bonding and Accreditation Deadlines for NCPA

NCPA has recently contacted CMS to obtain specifics regarding what pharmacists that have not yet obtained accreditation should know in deciding how to proceed.

  While a longer Q & A from our correspondence with CMS can be accessed here, and we advise you to review it, in a nutshell,

  1. Most pharmacies will need to obtain accreditation to participate in the DMEPOS program. Even those pharmacies that are only billing Part B drugs (and therefore do not need accreditation) must obtain a surety bond, if it bills the DME MAC
  2. A supplier (pharmacy) can obtain the accreditation certificate as late as September 28, and then carefully follow the procedures regarding mailing the amended CMS-855s to NSC, and thereby still meet the accreditation requirements. If he/she doesn't get one by that date, the pharmacy needs to voluntarily terminate.
  3. If a supplier gets an accreditation certificate after Oct. 1, it can at that time apply for re-enrollment. It then might take up to 60 days for the NSC to notify the pharmacy that the pharmacy can once again bill for DMEPOS - but the pharmacy can retroactively bill back to the date that it received the accreditation certificate.
  4. A pharmacy that does not meet the Oct. 1 deadline can choose to let CMS revoke its DMEPOS status, but by doing so, it would take the pharmacy longer to obtain DMEPOS billing status at a later date than if it voluntarily terminates.