Lexology February 14, 2022
Healthcare Alert
Providers are taking note of recent changes proposed by the Centers for Medicare & Medicaid Services (CMS) regarding payment rules and updates to certain policies in its Calendar Year (CY) 2022 Physician Fee Schedule (PFS) proposed rule. These broad revisions provide CMS with greater authority to revoke Medicare billing privileges.
Among these policies, proposed in July 2021, was a proposal related to provider enrollment to “increase [CMS’] flexibility to address periods of abusive billing that, though comparatively brief, have or could have harmed the Medicare program.” In making this proposal, CMS acknowledged that it sees itself as the “gatekeeper” to the Medicare program, preventing unqualified and potentially fraudulent individuals and entities from being able to enroll in and...