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CMS implements new rebuttal process for Medicare providers who have been deactivated

December 16, 2019
Area(s) of Interest: Practice Management 


The Centers for Medicare and Medicaid Services (CMS) has developed a new rebuttal process for providers whose Medicare enrollments have been deactivated. This new process begins on December 31, 2019, and gives providers the right to file a rebuttal to challenge their deactivation. Providers are given this opportunity to demonstrate that they meet all applicable enrollment requirements and that their Medicare billing privileges should not have been deactivated.

Deactivation Reasons

Only enrollments that are deactivated for the following reasons can be challenged through the new rebuttal process.

  • The provider or supplier did not submit Medicare claims for twelve consecutive calendar months.
  • They did not report a change of information within 90 calendar days of when the change occurred or within 30 days if it is an ownership change.
  • They did not respond to a revalidation request letter or to a request for corrections on a revalidation application.
  • They are in an approved status but have not had a practice location or active reassignment for 90 calendar days.

Submitting a Rebuttal

All rebuttals must be submitted within 20 calendar days from the date of the deactivation notice. These requests can be mailed, emailed or faxed to Noridian, California’s Medicare contractor. Any rebuttal submitted after the 20 calendar days will be dismissed.

Noridian is currently working on a coversheet that providers need to include with their rebuttal. This coversheet will be located on the Noridian Medicare website when finalized. Along with this coversheet, providers should include specific reasons for the rebuttal as well as all supporting documentation.

Rebuttals need to be signed by the individual provider, authorized or delegated official on file, or a legal representative. If the rebuttal submission is signed by an attorney, the attorney must also submit proof that they have the authority to represent the provider/supplier. Any missing information that is requested must be received with 30 days of the request or the rebuttal will be dismissed. If you are asked for a missing statement or appointment statement, the information must be received in 15 days.

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