By: Christopher A. Parrella, Esq., CPC, CPCO, CHC

Parrella Health Law, Bosto

As a healthcare defense and compliance firm, understanding the latest regulatory changes is crucial for advising our Medicare provider clients effectively. The Centers for Medicare & Medicaid Services (CMS) have announced significant updates to the Medicare Program Integrity Manual, effective January 1, 2024. These changes, detailed in MLN Matters Number: MM13331, impact various provider types and necessitate immediate action from billing staff.

Affected Providers:

• Marriage and Family Therapists (MFTs)
• Mental Health Counselors (MHCs)
• Physicians and other practitioners under the Physician Fee Schedule (PFS)
• All other Medicare provider and supplier types

Action Required:

Billing staff must be made aware of the following key changes:

• Medicare Enrollment for MFTs and MHCs: New policies are being implemented for their enrollment.
• Updates to Provider Enrollment Policies: These include new reasons for denial and revocation of enrollment.

Background:

Change Request (CR) 13331 updates Chapter 10 of the Medicare Program Integrity Manual. This is in line with the regulatory changes introduced in the Calendar Year (CY) 2024 Physician Fee Schedule (PFS) final rule.

Notable Changes:

• Authorized Officials: The definition has been clarified to specify that ‘organization’ refers to the legal entity enrolling with Medicare, identified by its legal business name and tax identification number.
• MFT and MHC Services: Starting January 1, 2024, Medicare will cover services provided by MFTs and MHCs, contingent on them meeting specific licensure and experience requirements.
• Group Practices and Reassignment: MFTs and MHCs will now have the option to opt-out of Medicare, form group practices, reassign benefits, and order/certify services as permitted by law.
• New Denial Reasons and Revocation Details: There are additional reasons for denial and detailed information on revocations, including their effective dates.

Additional Information:

Providers should thoroughly review all updates to Chapter 10 as outlined in CR 13331. CMS has instructed Medicare Administrative Contractors (MACs) to adhere to these changes.

Implications for Parrella Health Law Clients:

For our clients at Parrella Health Law, these updates are crucial. They not only redefine the enrollment and billing landscape but also present new compliance challenges and opportunities. We are poised to offer expert guidance to ensure that our clients – whether they are MFTs, MHCs, physicians, or other Medicare providers – navigate these changes seamlessly, maintaining compliance while optimizing their Medicare interactions.