We have heard recently from two members who had submitted change of ownership applications with DHCS provider enrollment. After visits from auditors requesting a variety of financial information but no apparent issues during their on-site visit they both received letters announcing that their applications were denied and provider numbers would be terminated in 20 days. They have the right to appeal. In both cases they were medical supply providers. There are several unique requirements for medical supply that have been in existence for many years and were the result of fraud and abuse problems that occurred decades ago, principally involving incontinence supplies. Those requirements are to have a place of business, open to the public with posted hours, have inventory, and the ability to process transactions. In the cases of both suppliers they were found to have technically not been in compliance with some or all of these elements. For example, no inventory in the reception area on display even though the attached warehouse had supplies in stock. As we said the appeals are in process but this is evidence of very strict compliance reviews by the DHCS auditors. CAMPS will be seeking legislative relief to reform these out-of-date standards that have no reflection on provider credibility.

Provider Enrollment has begun a series of stakeholder meetings over new procedures involving new applications or re-certifications of existing providers. Providers will be classified as limited, moderate or high risk applicants, with the latter requiring fingerprinting of any owners of 5% or more and criminal background checks. There may also be additional review procedures. The first announced high risk provider type is Drug Medi-Cal Providers which are drug rehabilitation clinics. We expect that DME/medical supply providers are candidates for classification as moderate or high risk. It might also mean a greater chance or more frequent need for revalidation of that provider type. That would mean time and money to complete the process. Federal law requires them to establish these categories and to establish additional review/evaluation procedures for providers based upon perceived risk. There is a public meeting later this week where we may obtain additional information.

Also this week DHCS had another stakeholder meeting on the progress with their automated web-based provider enrollment project known as PAVE. This will allow the application to be submitted on-line through a secure web portal with the ability to upload documents and determine status and completion. The goal is to speed up what is now a paper-only process that is slow and cumbersome. Initially targeted for roll out this fall, the start date has now been pushed back to February 27, 2015. One of the changes with Medi-Cal provider enrollment is a new application fee of $545. We will keep you informed on developments in all these areas.