Be Prepared for Medicare NPE Validation Visits – Part 2

In August 2024, we wrote about how to prepare for Medicare National Provider Enrollment (NPE) validation or revalidation visits. A continuing uptick in PTAN suspensions and revocations and recent revisions to the site investigation document makes preparing for these inspection visits with thorough planning and attention to detail more important than ever.

What exactly do you prioritize and why? Below are eight suggestions to prepare your organization for success with an NPE inspection.

1. Review the CMS requirement at 42 CRF 424.57(c). This is the full regulation that addresses supplier standards. Increasing your understanding of the focus of the validation/revalidation visit will benefit your efforts to prepare.
2. Review the site investigation document. This will detail what the inspector will be reviewing.
3. Consider presenting consolidated documentation. Providing all required documentation to inspectors in an organized format not only helps the site visit run more efficiently, it also keeps the focus on what is required to complete the investigation. This includes, but is not limited to:
   • A list of all owners/management.
   • Copies of all required company and personnel licenses.
     • If providing oxygen, include copies of the required licenses for your oxygen supplier(s).
   • Copy of current liability insurance.
   • Copy of current surety bond.
   • Complaint policy and sample log.
     • Ensure there is quick access to the current, updated complaint log.
   • Copies of contracts, invoices, or other verification demonstrating your ability to obtain inventory not kept on-site.
   • Copies of accreditation certificates for organizations contracted to deliver and educate patients on the organization’s products.
   • Copies of patient files documenting referral information, beneficiary communications, proof of delivery, maintenance/repairs/exchanges, warranty provision, rental or purchase option notification, written instructions on how to use Medicare covered items, and proof of patient receipt of DMEPOS Supplier Standards.
   • Copy of the organization’s phone number in a public directory.
   • Notify your staff. Make everyone aware that a site visit is expected and clarify the expectations of their roles during the visit. Staff should know who to notify as soon as the inspector arrives, be able to answer questions and provide necessary information.
4. Assign responsibility to key staff members to act as the point-of-contact for the inspector.
5. Rehearse the site visit. Prepare your team by conducting a mock site visit to simulate inspector requests and questions.
6. Prepare your facility.
   • Can the facility be easily accessed by all patients?
   • Are hours of operation posted?
   • Does the location meet size requirements mandated by supplier standards?
   • Do you have inventory onsite?
   • Are off-site storge locations ready for inspection?

Bonus Tip: Ensure that your investigation book (item 3) remains current by regularly reviewing its contents and replacing documents when new versions become available.

This process can help your organization complete or maintain its Medicare enrollment status and compliance with Supplier Standards. Preparation makes the inspection smoother and less stressful.

ACHC’s June issue of the DMEPOS Did You Know? e-newsletter will continue this series on preparing for Medicare NPE validation visits with a close look at managing complaint procedures.