Given the uncertainty of 2011 year-end congressional action to address the SGR, the Centers for Medicare & Medicaid Services (CMS) has extended the annual Medicare participation enrollment period through Feb. 14, 2012. The previous deadline was Dec. 31, 2011.
CMS notes that the effective date for any participation status change, however, will remain Jan. 1, 2012 and will be enforced for the entire year.
To help ensure that AADA member physicians are making informed decisions about their contractual relationships with the Medicare program, the AADA offers the following brief overview of the various participation options that are available to physicians.
The AADA is not advising or recommending any one of the three options described, but rather wants to ensure that physician decisions about Medicare participation are made with complete information about the available options.
Physicians who want to continue their current par or non-par status do not need to do anything to maintain their status. Those who want to switch their status need to notify their contractor in a written document. Notice must be post-marked on or before Feb. 14.
Participation options
There are three Medicare contractual options for physicians:
- PAR: Physicians may sign a PAR agreement and accept Medicare’s allowed charge as payment in full for all of their Medicare patients.
- Non-PAR: Physicians may elect to be a non-PAR physician, which permits them to make assignment decisions on a case-by-case basis and to bill patients for more than the Medicare allowance for unassigned claims.
- Private contract: Physicians may become private contracting physicians, agreeing to bill patients directly and forego any payments from Medicare to their patients or themselves.To become a private contractor, physicians must give 30 days notice before the first day of the quarter the contract takes effect.
Regardless of the participation change deadline date, a physician's participation decision will be retroactive to Jan. 1, 2012. Unless CMS reopens the enrollment period, the decision is binding throughout the calendar year except where the physician’s practice situation has changed significantly, such as relocation to a different geographic area or a different group practice.
Those considering a change in status should first determine that they are not bound by any contractual arrangements with hospitals, health plans or other entities that require them to be PAR physicians. In addition, some states have enacted laws that prohibit physicians from balance billing their patients.