Monday, April 18, 2016

FLASHING NEON HEADLINE: JUNE 1, 2016 IS THE DEADLINE…

By June 1, 2016, dentists must register as a Medicare ordering/prescribing provider of Part D prescription drugs for your Medicare-eligible patients or opt out of the program.  Just what does that mean for your practice?  There is much more at stake here than whether or not prescription drugs you prescribe for your Medicare-enrolled patients will be covered.

If you do not register with CMS (Centers for Medicare and Medicaid Services) or formally opt out of the program, your patients, your practice, the pharmacy filling prescriptions for your Medicare patients, the labs and specialists to whom you refer Medicare patients, durable medical equipment suppliers who might supply a sleep apnea device you order for a Medicare patient, etc., will not be paid by Medicare.  Incidentally, OPTING OUT as a Medicare provider requires action by the dentist---it is not the same as doing nothing.

In summary:

  •  If you do not register with CMS or formally opt out, drugs you prescribe for your patients enrolled in Medicare normally covered under Part D or Medicare Advantage plans will not be covered.
  • If you do not register with CMS or opt out, you will be unable to submit claims to Medicare Advantage plans, some of which do cover dental services.  Further, your Medicare patients cannot receive payment from their Medicare Advantage plan either.  And if you choose to opt out, neither you nor your patients can submit claims to their Medicare Advantage plans.
  • If a dentist takes no action by June 1, specialists and oral pathology laboratories to which you refer Medicare patients will not be paid by Medicare.  Ditto for imaging services and durable medical equipment suppliers.
  • If a dentist chooses to opt out, he/she must complete an affidavit to be sent to all Medicare contractors with whom he/she works.  If a dentist complies with opting-out procedures, specialists, laboratories, service and supply providers to whom Medicare patients are referred will receive payment from Medicare.  Additionally, Medicare patients can get their Part D prescription drugs covered by Medicare.

The easiest way to register with CMS is to complete CMS Form 8550 to become an “ordering/referring provider.”  The alternatives are:  (1) to register as a “Medicare Provider” using CMS Form 8551 or (2) to formally opt out of the program.  (Note the method and consequences of opting out listed above.)

These regulations, part of the Affordable Care Act (Obamacare is the commonly used name.), squeeze dentists between a rock and a hard place---either enroll as Medicare prescribers or providers which means they agree with rules, regulations, and guidelines of Medicare and can, therefore, be audited at any time by Medicare agents or forfeit the use of Medicare Advantage plans for their patients dental care, prescriptions, referrals, oral pathology work, etc.

Currently there is a bill active in Congress, H.R. 4062, that would exempt dentists from having to enroll in the Medicare program in order for prescriptions for Part D covered drugs to be paid under Medicare.  Suggestion: contact your U.S. Congress member to urge passage of the bill.

For additional information about enrollment/registration procedures or opting out of the program, go to Success.ADA.org/en/practice/medicare.  Move on this before the June 1 deadline!

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