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12/19/2003 |
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Carel T. Hedlund For 35 years or more, Medicare providers and suppliers have relied on the paper Manuals and Program Memoranda issued by CMS to identify Medicare policies and procedures with which they must comply. That is changing. Effective October 1, 2003, CMS began its transition from a paper-based manual system to a Web-based system. CMS anticipates the transition for Medicare Manuals will be completed by January 2004. The transition for the Medicaid Manuals will not be completed until the spring of 2004. Until such time as the phase-in process is completed, both sets of manuals will need to be checked for current policy and procedures. The online CMS manual system is available at www.cms.hhs.gov/manuals. The new online manual system is organized by functional area. According to CMS, this function orientation will eliminate significant redundancy among the manuals and streamline the updating process so that program instructions will be available in a more timely and accessible fashion. Specifically, the manuals will be organized according to the following functional areas: Pub. 100-01–Medicare General Information, Eligibility, and Entitlement Two existing manuals will stay the same. The contents of the Provider Reimbursement Manual (Pub. 15-1 and 15-2), including all of the cost-reporting instructions, and the Regional Office Manual (Pub. 23) will not migrate to a new manual. CMS will be revising its Web-based Manual webpage, however, so that the Provider Reimbursement Manual can be accessed online from that site. An overview "crosswalk" between the paper-based manuals and the Web-based manuals is provided in the Introduction in Publication 100. Each online manual includes a detailed crosswalk that shows how the information in each section was derived. Program instructions that impact multiple manuals or have no manual impact will be listed in Publication 100-20, "One-Time Notifications." Historically, changes to the various manuals have been announced by Program Transmittals. This will continue to be the case. Each change that is made to a Web-based Manual will also be announced by a Program Transmittal. The Program Transmittals can be accessed through the CMS Manual webpage. Each Program Transmittal will include a link to the new manual provisions, where the changes will be denoted in red italics. The public can subscribe to a listserv (a link to which is available through the CMS Manuals webpage) to be notified of each update. The Program Transmittals will permit providers and suppliers to track changes to manual sections over time. This can be very important because, in the course of an audit or investigation, the language of a prior version of a manual provision may be relevant in justifying a course of conduct. In addition to jettisoning the paper-based manual system, CMS has also discontinued as of October 1, 2003, the current practice of issuing Program Memoranda (PMs). Instead, CMS will use one of four new "vehicles/templates" to communicate program instructions and updates to the Web-based Manuals. These vehicles include (1) manual provisions, (2) one-time notifications, (3) business requirements, or (4) confidential requirement templates. CMS’s Office of Strategic Operations and Regulatory Affairs, Division of Issuances, will communicate advanced program instructions to the CMS Regional Offices and Medicare contractors every Friday. This new system is bound to cause some confusion among providers and suppliers, at least until such time as the transition is complete and they become accustomed to navigating the new Web-based Manuals. |
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Ober, Kaler, Grimes & Shriver Maryland
Washington, D.C. Virginia |
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