Just when we think things have leveled off, another change to a Medicare requirement has come forth by the Centers for Medicare & Medicaid Services (CMS) in regards to dentists who are enrolled for Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) services. Back in 2009, CMS published a final rule that required certain DMEPOS suppliers to obtain and maintain surety bond for no less than $50,000, on a continual basis. Non-physician practitioners and dentists were exempt from this requirement.
It has now been found there has been a spike in the enrollment of dentists for DMEPOS services. Dentists come into the equation when they are enrolled as a Medicare DMEPOS supplier and obtain a prescription from a physician, who has properly diagnosed and conducted a sleep study analysis for a shared patient. That patient is then referred to the dentist to have an oral appliance made for them. Since dentists are providing these appliances that have been prescribed by other providers, they no longer meet the requirements for exemption.
A DMEPOS supplier that does not qualify for an exemption must submit a surety bond to the CMS contractor within 60 days of receiving the letter from CMS, they no longer meet the criteria for exemption. Additional information can be found here: https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/MedicareProviderSupEnroll/DMEPOSEnrollment.html
Professional Insurance Programs, the wholly owned and operated insurance agency of the Wisconsin Dental Association, can assist members with securing this surety bond to submit to CMS for compliance. The requirement for each location to have is $50,000 surety bond. Please contact PIP for an application at 800-637-4676.
