The Centers for Medicare and Medicaid Services (CMS) recently released information regarding its new provider enrollment screening regulations, which contain a description of the scope of activities that contractors will perform during unannounced onsite visits to providers, including physical therapist practices. Physical therapists in private practice are not required to undergo site visits before they enroll in the Medicare program. However, they could be subject to unannounced site visits to ensure that providers are legitimate. Providers will be subject to requirements based on their assessed level of risk (limited, moderate, and high) as outlined in a new rule issued last month aimed at curbing fraud and abuse under Medicare, Medicaid, and the Children's Health Insurance Program.

Specifically, a contractor's report for an unannounced site visit will document the date and time of the visit and observations made at the facility, such as the facility was vacant and free of all furniture, a notice of eviction or similar documentation is posted at the facility, or the space is occupied by another company. The contractor also will photograph the provider or supplier for inclusion in the provider's file. In terms of the extent of the visit, the contractor will determine whether the following criteria are met: the facility is open; personnel are at the facility; customers are at the facility (if applicable to that provider or supplier type); and the facility appears to be operational. This will require the site visitor(s) to enter the provider's practice or the supplier's site rather than simply conducting an external review. If any of the 4 elements listed above are not met, the provider's enrollment application may be denied or Medicare billing privileges revoked.