A recent audit conducted by the Office of Inspector General (OIG) identified inconsistent billing practices in which both Critical Access Hospitals (CAHs) and physician practices billed for professional services when the CAH had elected Method II billing. As a result of this audit, CMS will be implementing system edits to prevent duplicate payments for CAHs and individual providers.
When Does the New Method II Billing Requirement Take Effect?
Effective July 1, 2025, CAHs that have elected Method II billing will be subject to a claim edit to verify that the attending or rendering provider included on the UB-04 claim form has been reassigned to the hospital in the Provider Enrollment, Chain, and Ownership System (PECOS). Failure to complete these reassignments will result in claim denials. A copy of the Change Request related to this requirement can be found here.
What Should CAHs Do?
CAHs that have elected Method II billing for professional services should immediately review the reassignments in their enrollment record. Hospitals that identify providers for whom a reassignment is not present should complete the reassignment in PECOS and send it to their Medicare Administrative Contractor (MAC) for approval. Both the individual provider and the CAH’s authorized official will need to sign any new reassignments created to comply with this new requirement.
How Forvis Mazars Can Help
Our professionals at Forvis Mazars have extensive experience helping CAHs and other rural providers with billing, compliance, and other revenue cycle challenges. If you have any questions about the new reassignment requirement or would like assistance complying with the requirement, please reach out to our team.