It’s everyone’s favorite time of the year. No, not college football (still stings to think about that), but HRSA’s annual recertification for hospitals. This year, HRSA has provided updated registration and recertification requirements. This blog is not intended to cover every aspect of recertification, but a few tips and thoughts as you prepare to get this off your to do list. Below are some key points to share on the different aspects of recertification.
When: If you are a hospital 340B covered entity, for 2020 you must recertify between August 17th and September 14th.
Who: Authorizing Officials (AO) can complete in one login session OR the Primary Contact (PC) can do the bulk of the verification with the AO logging in separately and attesting to it. AO’s must complete their attestation by September 14th.
- “340B OPAIS will prompt Authorizing Officials and Primary Contacts (AOs and PCs) to upload supporting documentation for the “Hospital Classification” selected at the time of registration of a parent hospital.”
- The Medicaid billing question is modified as follows: “At this site, will the covered entity bill Medicaid fee-for-service for drugs purchased at 340B prices?” If the 340B covered entity site (340B ID) answers “yes” to this question, the site must also provide each Medicaid state it plans to bill and the billing number(s) it will list on the bill to the state.
- See Medicaid section below for more details if you Carve-In
Recertification Guidelines: The purpose of recertification is to simply validate information in OPAIS. Thus, you may edit database information and terminate existing child sites/contract pharmacies. However, you may NOT register new child sites or add contract pharmacies.
Login/Communication: AO’s will get daily reminders to attest the work completed by a PC. Don’t rely on this email to communicate the AO’s responsibility. Be sure to communicate with the AO in other means so he/she knows of the needed task. And most likely, the AO will need to change their password, so be prepared for that very important task (aka. waste of time).
- Medicare Cost Report (MCR) signed Worksheet S: filling details
- MCR Worksheet E, Part A: DSH percentage
- Worksheet S-3 for children’s hospitals
- MCR Worksheet S-2: hospital type
- MCR Worksheet A and C: outpatient facility registration
- Employer Identification Number (EIN)
- Medicaid Billing Information: NPI and state Medicaid numbers
- Government Contract: make sure it is effective
***If MCR data does not match OPAIS/CMS database information, be prepared to submit pdf or excel versions of the above***
Once logged in:
- Start at the parent and then go through each child site. This will cascade important information down vs. input at each child site.
- Government Official: Be prepared to update this information with relevant name, phone, email of key contact.
- Hospital Control Type: Compare to status on MCR Worksheet S-2, Line 21
- Verifying DSH %: MCR Worksheet E, Part A, Line 33 (S-3 for Children’s hospitals)
- Child Sites: Verify each still exist on MCR with outpatient revenue and expenses
- Medicaid Information: This is the largest change from previous years. HRSA expects that for every state you carve-in, you have that listed separately with your NPI, Medicaid, or both numbers (whichever you actually submit on the bill). This is for each state.
- During recertification, you can complete this section by simply selecting the states for the NPI/Medicaid numbers you already have registered.
- However, if you want to get it on the next MEF as HRSA expects, you will need to do this through a change request now, during recertification or prior to September 15th.
- Important note, your duplicate discount risk may or may not change with this requirement as states will continue with their specific policies. For example, a state may continue to rely on the CE’s NPI number at the parent level no matter which state it is assigned to in OPAIS. However, any omissions can be considered a database finding in the future.
***Preventing duplicate discounts is a vital aspect of program integrity and should be assessed comprehensively and separately outside of recertification***
- Key message here is that HRSA wants you to be transparent on which states you are carving in and what numbers you bill with: NPI, Medicaid, or both.
Other Random Points:
- Make sure you actually hit SUBMIT at the end of recertification!!
- Pay attention to pop-ups. They are not annoying alerts, but have impactful messaging.
- Don’t help your PC/AO over Zoom video. It will make them uncomfortable when they search for their password and type it in wrong a few times.
As always, we are your partner and can answer any specific questions you may have!