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May 12, 2023

What’s Going to Happen to Temporary Medicare Provider Enrollments Now That the COVID Public Health Emergency Has Ended?

This Bulletin is brought to you by AHLA’s Regulation, Accreditation, and Payment Practice Group.
  • May 12, 2023
  • Louise M. Joy , Joy & Young LLP
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Remember the chaos in 2020. There was a lot of uncertainty and lots of moving parts trying to care for so many people who were sick with COVID and the need to move health care providers to the COVID hotspots. The Centers for Medicare & Medicaid Services (CMS) worked very hard to create flexible solutions to assist medical groups and practitioners enroll in Medicare as quickly as possible. 

One of the solutions was the availability of temporary provider enrollments, or provider transaction access numbers (PTANs), that could be obtained by phone from the Medicare Administrative Contractor. Now that the Pandemic Health Emergency Declaration came to an end on May 11, 2023, you may be wondering what will happen to the temporary PTANs.

The guidance during the pandemic stated as follows:

Will my temporary Medicare billing privileges be deactivated once the public health emergency is lifted? Medicare billing privileges established via the Medicare Provider Enrollment Hotline are being granted on a provisional basis as a result of the public health emergency declaration and are temporary. Upon the lifting of the COVID-19 PHE declaration, providers and suppliers will be asked to submit a complete CMS-855 enrollment application in order to establish full Medicare billing privileges. Failure to respond to the MAC’s request within 30 days of the notification will result in the deactivation of your temporary billing privileges. No payments can be made for services provided while your temporary billing privileges are deactivated.[1]

With the end of the public health emergency, we sought clarification about what will happen with temporary PTANs. Here’s the information that we got from CMS:

  1. Will practitioners with temporary PTANs get a separate notice about when to submit the 855 enrollment? Yes. The MACs will begin issuing letters on June 1st.
  2. Will they have 30 days from the notice or from today to submit the 855 enrollment? Providers will have 90 days from the notice to respond. (It’s nice to see that CMS is being more flexible than originally planned.)
  3. Will the Temporary PTANs deactivate May 11 at midnight? No. The temporary PTANs will only be deactivated if you don’t respond to the MAC’s notice.
  4. Will they need to submit the applications in paper if they cannot submit the full enrollment in PECOS? Providers should be able to submit via PECOS or paper. If using PECOS, select the revalidation option and validate all sections are complete and accurate. The MACs will assign the permanent PTAN once processing is complete.
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