Medicaid Provider Enrollment Update

Many NYSOA members may have received notices from Medicaid managed care plans that you are required to enroll in the Medicaid program in order to continue to participate in Medicaid managed care networks. Under the updated federal Medicaid managed care regulations, providers enrolled in managed care plan networks that are ordering, referring or furnishing services must be screened and enrolled by State Medicaid programs by 2019. The 21st Century Cures Act further expanded and expedited these requirements, compelling providers enrolled in managed care plan networks that are providing services to, or ordering, prescribing, referring, or certifying eligibility for Medicaid beneficiaries to be screened and enrolled by State Medicaid programs by January 1, 2018. Managed care plans are required to terminate participation of any providers that have not enrolled in the New York State Medicaid program.

At our October meeting, Manatt, NYSOA’s outside counsel, gave an update on this requirement and the State’s efforts to implement and enforce this rule. At the time the Department of Health had directed the managed care plans to stop engaging in outreach to contracted providers and indicated that implementation of the new rule would be delayed. Since that time the Department of Health has instructed plans to restart outreach with providers and provided additional information on how enforcement of the requirement will be handled.

Optometrists participating in Medicaid managed care that have not yet enrolled in the State Medicaid program should apply as soon as possible. The Department of Health has directed plans (including those offering mainstream managed care, managed long term care products and the Children’s Health Insurance Program products) to begin terminating contracts of providers that have not enrolled in the Medicaid program in April 2018. Given that the 21st Century Cures Acts provides the State with between 90 and 120 days to reach a determination once an application has been received (an additional 30 days is provided where Medicare enrollment is required), an application must have been submitted by December 1, 2017 to ensure enrollment by April 1, 2018. However, eMedNY will continue to receive and process enrollments received in January and the Department of Health has directed plans not to terminate providers who have pending enrollment prior to January 2018. More information can be found on the eMedNY website.

The Department of Health is exploring options to provide interim steps short of termination in order to allow providers additional time to enroll, and we will provide updates on those alternatives as we become aware of them. If you have any follow-up questions on this issue, please direct them to Megan Sherman at Manatt, Phelps & Phillips, LLP, Phone: (518) 431-6707, Email: MSherman@manatt.com.

-posted December 27, 2017

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