pending pre site visit

Pre-enrollment Site Visit Required for HCS and TxHmL Providers That Enrolled Through PEMS

by Julie Blacklock | Dec 1, 2022

December 1st, 2022

Home and Community-based Services and Texas Home Living waiver program providers that enrolled through the Texas Medicaid and Healthcare Partnership Provider Enrollment and Management System will be subject to a pre-enrollment site visit from TMHP. Read the full alert .

Home and Community-based Services (HCS) and Texas Home Living (TxHmL) waiver program providers that enrolled through the Texas Medicaid & Healthcare Partnership (TMHP) Provider Enrollment and Management System (PEMS) will be subject to a pre-enrollment site visit from TMHP .

The pre-enrollment site visit is required for enrollment in Texas Medicaid. The HCS program site visits will be conducted at the locations listed on the enrollment application, including the business office and any locations where clients receive residential assistance services.

A TMHP site visit coordinator will reach out through email or phone to schedule a visit. If the TMHP site visit coordinator is unable to reach the provider, then TMHP will conduct an unannounced site visit.

If providers have questions, contact the TMHP LTC Help Desk at 800-626-4117 (select option 1 and then option 7)

A few items I want to make you aware of if you are a new HCS/TxHmL Provider Applicant:

•   i.e. TMHP billing specialist, or billing agency, someone at your agency using only TMHP or also specific outside software to make it easier to monitor and complete your billing (i.e. Millen Pro Billing services and/or software), or via Electronic Health Records for instance that have TMHP and EVV billing capabilities (TaskMaster Pro, TMHP, etc..)
• You do not have to have a group home when they visit before you have a contract.  You don’t have clients yet and HCS does not require you to purchase or rent a home prior to receiving your contract. (Adult Mental Health HCBS program does require you have a home)
• You do not have to have a rented business office or “storefront”.  You can use your “home office”.  But you may need to explain how you intend to see your clients, meet potential families and clients or do staff trainings and still maintain privacy.  Perhaps you can ask your local LIDDA’s if they have meeting spaces available to the providers, or you may use virtual office space, hotel conference/meeting rooms, and any staff training for group homes that will happen in the group home for example..
• Make sure if it is a home office, that it really is a delegated space for your office.
• They may want to know how you plan to maintain privacy and security with client records electronically stored, transferred, shared, or disposed of.
• They may request a few policies (security and privacy inquiry form policies and procedures, complaint process, etc..) please contact me if you want a list of the rest or if you want to hire us to provide some of them for you. Twogether Consulting Ph: 512-294-8032 

Upcoming Events

• Visit TexasChildrensHealthPlan.org
• 1-800-731-8527
• Electronic Visit Verification (EVV)
• Clinical Practice Guidelines
• Downloadable Forms
• Provider Directory
• Provider Resources
• Quick Reference Guide
• STAR Kids Information
• The Checkup Newsletter
• 2019 Annual Provider Newsletter
• Provider Events

Provider Alert! UPDATE: Provider Enrollment and Management System (PEMS) Provider Guidance

Date: August 16, 2022

Attention: All Providers

Providers should monitor the Texas Children’s Health Plan (TCHP) Provider Portal regularly for alerts and updates associated with the COVID-19 event. TCHP reserves the right to update and/or change this information without prior notice due to the evolving nature of the COVID-19 event.

UPDATE on the provider effective dates: Prior to the Provider Enrollment and Management System (PEMS) implementation, the provider billing effective date could be the Medicare enrollment effective date, the provider license date, or the application completion date (retroactive billing date).

With PEMS implementation, new and reenrolled provider agreement effective dates were upon signature of the agreements and required all screenings to be completed. After further review, HHSC, in collaboration with the Office of Inspector General (OIG) made the decision to allow retrospective billing effective dates in certain circumstances, as outlined in the attached table. The new policy applies to new enrollments and reenrollments only.

Retroactive Billing Allowances Table

Reminder on PEMS information overall: Texas Children’s Health Plan (TCHP) would like to offer guidance regarding the Provider Enrollment and Management System (PEMS). As a reminder, PEMS is a newly required Texas Medicaid & Healthcare Partnership (TMHP) program that went live December 13, 2021 as the single tool for provider enrollment, reenrollment, revalidation, and maintenance requests (maintaining and updating provider enrollment record information).

Resource: https://www.tmhp.com/topics/provider-enrollment

How this impacts providers: TCHP will contract, credential and pay only those providers that we receive in the official file from the State after they have successfully enrolled in PEMS. In addition, every provider must be enrolled at each location where they see patients. This is help to ensure providers are properly contracted with TCHP and their claims process correctly.

Next steps for providers: PEMS is accessed through My Account, https://secure.tmhp.com/MyAccount/default.aspx. PEMS access is tied to the National Provider Identifier (NPI) or Atypical Provider Identifier (API) associated with the TMHP user account. Ensure that the NPI has all the current and correct information. After a TMHP user account is created, follow these best practices for account management:

• Assign at least two administrators.
• Update user permissions as staff changes occur.
• Look for reminders for upcoming enrollment tasks on the Message Dashboard.

More information on provider enrollment identification:

• PEMS bases each enrollment application on the applying provider’s NPI or API.
• Providers who would like to enroll in Texas health-care programs must do so under one of two categories, individual or organization, determined by their NPI or API.

National Provider Identifier:

• Individual providers, performing providers, and sole proprietors will enroll in PEMS with an NPI type

of Individual.

• Facility and group health-care providers who have a single employee or thousands of employees will enroll in PEMS with an NPI type of Organization.
• NPIs are obtained from the National Plan and Provider Enumeration System (NPPES).

Atypical Provider Identifier:

• Providers or individuals who do not provide health-care services and are not required to have NPIs may have been issued Atypical Provider Identifiers (APIs). These providers should use their APIs for enrollment purposes.

Texas Medicaid and Other Programs and Services Enrollment Types

The affected enrollment types are:

• Acute Care Services
• Comprehensive Care Program (CCP)
• Texas Health Steps Dental
• Texas Health Steps Medical
• Healthy Texas Women (HTW)
• Case Management
• Texas Health and Human Services Commission (HHSC) Long-term Care (LTC)
• Managed Care Organizations – Long-Term Services and Supports (MCO-LTSS)
• Pharmacy Services
• Medical Transportation Program (MTP)
• Kidney Health Care (KHC)
• Children with Special Health Care Needs (CSHCN) Services Program
• CSHCN Family Support Services (FSS)
• Children’s Health Insurance Program (CHIP)

Provider Requirements

Providers can view and confirm their revalidation date and enrollment information in PEMS on this site https://www.tmhp.com/topics/provider-enrollment/pems/npi-type-and-program-selection . Here is the link to the overall enrollment site, https://www.tmhp.com/topics/provider-enrollment/pems/start-application. To reduce application time, we encourage providers to have the following information available:

• First and last name
• Organization name
• Social Security number
• Date of birth
• Employer’s Tax Identification Number and legal name
• Licenses or certifications, if applicable
• Identification for the provider and any person who meets the definition of owner, creditor, principal, subcontractor, or managing employee
• Documentation related to disclosures, if needed
• Additional documentation required for program participation

Providers revalidating an existing enrollment should continue to submit claims to meet their timely filing requirements. Resources:

• For provider enrollment help, visit this site https://www.tmhp.com/topics/provider-enrollment/provider-enrollment-help .
• Texas Medicaid Provider Procedures Manual, Provider enrollment and Responsibilities, https://www.tmhp.com/sites/default/files/file-library/resources/provider-manuals/tmppm/pdf-chapters/2022/2022-06-june/1_01_Provider_Enrollment.pdf

If you have any questions, please email Provider Network Management at: [email protected] .

For access to all provider alerts, log into : www.thecheckup.org or www.texaschildrenshealthplan.org/for-providers

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Medicare Provider Enrollment Print

What’s Changed?

• Updated the enrollment application fee amount for 2024
• Added marriage and family therapists, mental health counselors, and certain dental specialties to the Part B suppliers list
• Merged Form CMS-855R into the CMS-855I paper enrollment application
• Added new provider specialty code information for dentists

Substantive content changes are in dark red.

Application Fee

Physicians, non-physician practitioners, physician organizations, non-physician organizations, and Medicare Diabetes Prevention Program suppliers don’t pay a Medicare enrollment application fee.

Generally, institutional providers and suppliers like DMEPOS suppliers and opioid treatment programs pay an application fee when enrolling, re-enrolling, revalidating, or adding a new practice location.

Enrollment Application Fee

The 2024 enrollment application fee is $709.

Whether you apply for Medicare enrollment online or use the paper application, you can pay the Medicare application fee online through:

• PECOS: During the application process, PECOS prompts you to pay the application fee
• CMS Paper Application: Go to PECOS Application Fee Information to submit the application fee

A hardship exception exempts you from paying a current application’s fee. If you request a hardship exception, submit a written request and supporting documentation describing the hardship and justifying an exception to paying the application fee with your PECOS or CMS paper application. We grant exceptions on a case-by-case basis.

Medicare Administrative Contractors (MACs) will only process applications with the proper application fee payment or an approved hardship exception.

If you don’t pay the fee or submit a hardship exception request, your MAC will send a letter allowing you 30 days to pay the fee. If you don’t pay the fee on time, the MAC may reject or deny your application or revoke your existing billing privileges, as appropriate.

Providers must enroll in the Medicare Program to get paid for providing covered services to Medicare patients. Determine if you’re eligible to enroll and how to complete enrollment.

We list institutional providers on the Medicare Enrollment Application: Institutional Providers (CMS-855A) , which include:

• Community mental health centers
• Comprehensive outpatient rehabilitation facilities
• Critical access hospitals
• ESRD facilities
• Federally Qualified Health Centers
• Histocompatibility labs
• Home health agencies
• Hospice organizations
• Indian Health Service facilities
• Organ procurement organizations
• Opioid treatment programs
• Outpatient physical therapy, occupational therapy, speech pathology services
• Religious nonmedical health care institutions
• Rural emergency hospitals
• Rural health clinics
• Skilled nursing facilities (SNFs)

Physicians, non-physician practitioners (NPPs), clinics or group practices, and specific suppliers who can enroll as Medicare Part B providers are defined in enrollment forms Medicare Enrollment Application: Physicians and Non-Physician Practitioners (CMS-855I) and Medicare Enrollment Application: Clinics/Group Practices and Other Suppliers (CMS-855B) .

Who’s an NPP?

NPPs include nurse practitioners, clinical nurse specialists, and physician assistants who practice with or under a physician’s supervision.

Physicians, NPPs, & Suppliers (CMS-855I)

• Anesthesiology assistants
• Audiologists
• Certified nurse-midwives
• Certified registered nurse anesthetists
• Clinical nurse specialists
• Clinical psychologists
• Clinical social workers
• Marriage and family therapists
• Mass immunization roster billers (individuals)
• Mental health counselors
• Nurse practitioners
• Occupational or physical therapists in private practice
• Dental anesthesiology
• Dental public health
• Endodontics
• Oral and maxillofacial surgery
• Oral and maxillofacial pathology
• Oral and maxillofacial radiology
• Oral medicine
• Orofacial pain
• Orthodontics and dentofacial orthopedics
• Pediatric dentistry
• Periodontics
• Prosthodontics
• Physician assistants
• Psychologists billing independently
• Registered dietitians or nutrition professionals
• Speech-language pathologists

Clinics, Group Practices, & Specific Suppliers (CMS-855B)

• Ambulatory surgical centers (ASCs)
• Clinics and group practices
• Home infusion therapy suppliers
• Hospital departments
• Independent clinical labs
• Independent diagnostic testing facilities
• Intensive cardiac rehabilitation suppliers
• Mammography centers
• Mass immunization roster billers (entities)
• Physical or occupational therapy groups in private practice
• Portable X-ray suppliers
• Radiation therapy centers

Medicare Diabetes Prevention Program Suppliers

Potential suppliers must use Medicare Enrollment Application: Medicare Diabetes Prevention Program (MDPP) Suppliers (CMS-20134) to enroll in the Medicare Program.

Beginning January 1, 2024, we established new provider specialty codes for dentists.

If you don’t see your provider type listed, contact your MAC’s provider enrollment center before submitting a Medicare enrollment application.

Medicare provider and supplier organizations have business structures, like corporations, partnerships, professional associations, or limited liability companies, which meet the provider and supplier definitions. Provider and supplier organizations don’t include organizations the IRS defines as sole proprietorships.

Provider and supplier organizations include:

• Medical group practices and clinics

You must have a provider or supplier employer identification number (EIN) to enroll in Medicare. An EIN is the same as the provider or supplier organization’s IRS-issued tax identification number (TIN).

Sole Proprietorships & Disregarded Entities

Sections 10.6.4 and 10.6.7.1(D)(5) of Medicare Program Integrity Manual, Chapter 10 have more information about sole proprietorships and disregarded entities.

Medicare participation means you agree to accept claims assignment for all covered patient services. By accepting assignment, you agree to accept Medicare-allowed amounts as payment in full. You can’t collect more from the patient than the deductible and coinsurance or copayment . The Social Security Act says you must submit patient Medicare claims whether or not you participate.

You have 90 days after we send your initial enrollment approval letter to decide if you want to be a participating provider or supplier. To participate as a Medicare Program provider or supplier, submit the Medicare Participating Physician or Supplier Agreement (CMS-460) upon initial enrollment. The only other time you may change your participation status is during the open enrollment period, generally from mid-November–December 31 each year.

Participating Provider or Supplier

• We pay 5% more to participating physicians and other suppliers
• Because these are assigned claims, we pay you directly
• We forward claim information to Medigap (Medicare supplement coverage) insurers

Non-Participating Provider or Supplier

• We pay 5% less to non-participating physicians and other suppliers
• You can’t charge patients more than the limiting charge, 115% of the Medicare Physician Fee Schedule amount
• You may accept assignment on a case-by-case basis
• You have limited appeal rights

Medicare Claims Processing Manual, Chapter 12 has more information.

Step 1: Get an NPI

To enroll in the Medicare Program, get an NPI through:

• Online Application: Get an Identity & Access Management (I&A) System user account. Then apply for an NPI in NPPES .
• Call 1-800-465-3203 (TTY 1-800-692-2326)
• Email [email protected]
• Bulk Enumeration: Apply for Electronic File Interchange access and upload your own CSV or XML files.

Not Sure If You Have an NPI?

Search for your NPI on the NPPES NPI Registry .

CMS Provider Enrollment Systems:

• I&A System
• Electronic Health Record (EHR) Incentive Payments

Multi-Factor Authentication

To better protect your information, we implemented I&A System multi-factor authentication for the provider enrollment systems listed above.

Step 2: Complete Proper Medicare Enrollment Application

After you get an NPI, you can complete Medicare Program enrollment, revalidate your enrollment, or change your enrollment information. Before applying, get the necessary enrollment information , and complete the actions using PECOS or the paper enrollment form.

A. Online PECOS Application

After we approve your I&A System registration, submit your PECOS application.

PECOS offers a scenario-driven application, asking questions to recover the information for your specific enrollment scenario. You can use PECOS to submit all supporting documentation. Follow these instructions:

• Log in to PECOS .
• Continue with an existing enrollment or create a new application.
• When PECOS determines your enrollment scenario and you confirm it’s correct, you’ll see the topics for submitting your application. To complete each topic, enter the necessary information.
• Confirms you entered all necessary data
• Lists MAC documents to submit for review
• Gives the option to electronically sign and certify
• Shows your MAC’s name and mailing address
• Lets you print your enrollment application for your records (don’t submit a paper copy to your MAC)
• Sends the application electronically to your MAC
• Emails you to confirm your MAC got the application

PECOS 2.0 Enhancements

PECOS will have enhanced features to better meet your needs. Watch this 2-minute video or read these FAQs to learn more about:

• A single application for multiple enrollments
• Data pre-population and an application that’s tailored to you
• Enhanced capability to add or delete group members
• Real-time processing checks and status updates
• Revalidation reminders

Visit Introducing PECOS 2.0 for more information.

PECOS Scroll Functionality

PECOS validates that you’ve read and acknowledged certification terms and conditions before you electronically submit your Medicare enrollment application. Review and scroll through each text box with certification requirements before you can select accept on these pages:

• Remote E-sign

Enrolling physicians, NPPs, or other Part B suppliers must choose 1 of the application descriptions below.

• You’re the only owner of a business, set up as a corporation, where you provide health care services
• Your business is legally separate from your personal assets
• You provide all health care services from a facility you own, lease, or rent
• You’re the only owner of a business that provides health care services
• You and your business are legally 1 and the same
• You’re personally responsible for the business’ financial obligations, and you report business income and losses on your personal tax return
• You provide all health care services as an employee of a group practice or clinic
• You arrange with your employer to submit claims and get paid for your services
• Choose Group Member Only if you’re reassigning all your benefits to a group practice or clinic
• You provide health care services as a group practice or clinic employee
• You agree with your employer to submit claims and get paid for your services
• You also provide health care services from a facility that you own, lease, or rent
• Your income through self-employment is part of your personal assets
• Your corporation doesn’t file taxes; instead, you file corporate taxes on your personal tax filing

B. Paper Medicare Enrollment Applications

Submit the appropriate paper enrollment application if you’re unable to use PECOS. Carefully review the paper application instructions to decide which form is right for your practice. The paper enrollment application collects your information, including documentation verifying your Medicare Program enrollment eligibility.

If you submit a paper application, your MAC processes your application and creates a Medicare enrollment record by entering the data into PECOS.

Medicare Enrollment Application: Institutional Providers (CMS-855A) : Institutional providers use this form to begin the Medicare enrollment or revalidation process or to change enrollment information.

Most physicians and NPPs complete the CMS-855I to begin the enrollment process. You can also use the CMS-855I if you reassign your benefits to another entity, like a medical group or group practice that gets paid for your services. We’ve merged the CMS-855R into the CMS-855I paper enrollment application.

• Medicare Enrollment Application: Clinics/Group Practices and Other Suppliers (CMS-855B) : Group practices and other organizational suppliers, except DMEPOS suppliers, use this form to begin the Medicare enrollment or revalidation process or to change enrollment information.
• Medicare Enrollment Application: Enrollment for Eligible Ordering/Certifying Physicians and Other Eligible Professionals (CMS-855O) : Physicians and other eligible NPPs use this form to enroll in Medicare solely to order or certify items or services for Medicare patients. This includes those physicians and other eligible NPPs who don’t send billed services claims to a MAC.
• Medicare Enrollment Application: Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Suppliers (CMS-855S) : DMEPOS suppliers use this form to begin the Medicare enrollment or revalidation process or to change enrollment information.
• Medicare Enrollment Application: Medicare Diabetes Prevention Program (MDPP) Suppliers (CMS-20134) : MDPP suppliers use this form to begin the Medicare enrollment or revalidation process or to change enrollment information.

After you submit an enrollment application and all required supporting documentation to your MAC, they’ll send their recommendations to the State Survey Agency . The State Survey Agency then decides if specific providers meet Medicare enrollment conditions.

After a MAC makes a recommendation, the State Survey Agency or a CMS-recognized accrediting organization conducts a survey. Based on the survey results, the agency or organization recommends that we approve or deny the enrollment (certification of compliance or non-compliance).

Certain institutional provider types may elect voluntary accreditation by a CMS-recognized accrediting organization instead of a State Survey Agency. The accrediting organization will notify the State Survey Agency of their decision.

The State Survey Agency forwards us the survey results. We assign the CMS Certification Number and effective date, sign the provider agreement, and update the certification database. Your MAC will issue your final approval or denial letter.

If approved, you’ll get a fully executed provider agreement.

Electronic Funds Transfer

If enrolling in Medicare, revalidating, or making certain changes to your enrollment, we require you to set up an electronic funds transfer (EFT). Enroll in EFT by completing the PECOS EFT information section. When submitting a PECOS application:

• Complete the EFT information for your organization (if appropriate) or yourself
• Include a copy of a voided check or bank letter that has your individual or business legal name and applicable account and routing numbers

Step 3: Respond to Requests for More Information

MACs pre-screen and verify enrollment applications for completeness. If the MAC needs more information, respond to information requests within 30 days. If you don’t, the MAC may reject your enrollment .

Your MAC won’t fully process your PECOS enrollment application without your electronic or uploaded signature, application fee (if applicable), and necessary supporting documentation. The enrollment application filing date is when the MAC gets your enrollment application.

You can check your PECOS enrollment application status 2 ways:

• Log in to PECOS and select the View Enrollments link. In the Existing Enrollments section, find the application. The system shows the application status.
• To see your enrollment status without logging in, go to PECOS and, under Helpful Links , select Application Status.

When your MAC approves your application, it switches the PECOS record to an approved status and sends you an approval letter.

Provider Enrollment Site Visits

We conduct a site visit verification process using National Site Visit Contractors (NSVCs). A site visit helps prevent questionable providers and suppliers from enrolling or staying enrolled in the Medicare Program.

The NSVCs conduct unannounced site visits for all Medicare Part A and B providers and suppliers, including DMEPOS suppliers. The NSVCs may conduct an observational site visit or a detailed review to verify enrollment-related information and collect other details based on pre-defined CMS checklists and procedures.

During an observational visit, the inspector has minimal contact with the provider or supplier and doesn’t hinder the facility’s daily activities. The inspector will take facility photos as part of the site visit. During a detailed review, the inspector enters the facility, speaks with staff, and collects information to confirm the provider’s or supplier’s compliance with our standards.

Inspectors performing site visits will carry a photo ID and a CMS-issued, signed authorization letter the provider or supplier may review. If the provider or its staff want to verify we ordered a site visit, contact your MAC .

Make your office staff aware of the site visit verification process. An inspector’s inability to perform a site visit may result in denial of your Medicare enrollment application or revocation of your Medicare billing privileges.

Step 4: Use PECOS to Keep Enrollment Information Current

Report a Medicare enrollment change using PECOS. Physicians, NPPs, and physician and NPP organizations must report a change of ownership or control (including a change in authorized or delegated official), a change in practice location, and any final adverse legal actions (like a felony or suspension of a federal or state license) within 30 days of the change and report all other changes within 90 days of the change.

DMEPOS suppliers must report changes in their enrollment application information within 30 days of the change.

Independent diagnostic testing facilities must report changes in ownership, location, general supervision, and adverse legal actions within 30 days of the change and report all other changes within 90 days of the change.

Medicare Diabetes Prevention Program suppliers must report changes in ownership, including AO or Access Manager; location; coach roster; and adverse legal actions within 30 days of the change and report all other changes within 90 days of the change.

PECOS Users

We allow various organizations and users to work in our systems. The type of user depends on their relationship with you and the duties they perform in your practice.

You may choose other users to act for your organization to manage connections and staff, including appointing and approving other system-authorized users. Depending on your professional relationships with other providers, the CMS External User Services Help Desk may ask you for additional validation information.

One Account, Multiple Systems

We use several provider enrollment systems. Organizational providers and suppliers must use the Identity & Access Management (I&A) System to name an AO to work in CMS systems. The I&A System allows you to:

• Use NPPES to apply for and manage NPIs
• Use PECOS to enroll in Medicare or update or revalidate your current enrollment information
• Register to get electronic health record (EHR) incentive payments for eligible professionals and hospitals that adopt, use and upgrade, or show meaningful use of EHR technology

Authorized Officials, Access Managers, Staff End Users, & Surrogates

Organizational providers or suppliers must appoint and authenticate an Authorized Official (AO) through the I&A System to work in PECOS for them. That person must meet the AO regulatory definition. For example, an AO is a chief executive officer, chief financial officer, general partner, chair of the board, or direct owner who can legally enroll in the Medicare Program.

Respond to your employer’s AO invitation or initiate the request yourself. After you’re the confirmed AO, use PECOS for your provider or supplier organization. As an AO, you’re responsible for approving PECOS user system requests to work on behalf of the provider or supplier organization. Regularly check your email and take the requested actions.

AOs may delegate their responsibilities to an Access Manager who can also initiate or accept connections and manage staff for their organizations.

AOs or Access Managers may invite a Staff End User (SEU) or Surrogate to access PECOS for their organization. Once registered, an SEU or Surrogate may log in to access, view, and modify CMS system information, but they can’t represent the practice, manage staff, sign enrollment applications, or initiate or accept connections.

We recommend using the same I&A System-appointed AO and PECOS Access Managers. The assigned AO and Access Managers must have the right to legally bind the company and be responsible for approving the system staff and be CMS-approved in the I&A System.

Only AOs can sign an initial organization enrollment application. An Access Manager can sign changes, updates, and revalidations.

The I&A System Quick Reference Guide has detailed instructions on managing system users.

PECOS Technical Help

Using PECOS may require technical support. The first step toward a solution is knowing which CMS contractor to contact.

Common Problems & Who to Contact

You experience system-generated error messages, have trouble navigating through or accessing PECOS screens, encounter printing problems, or your valid I&A System user ID and password won’t allow PECOS access because of a malfunction (for example, the website operates slowly or not at all or a system-generated error message prevents you from entering data).

A system-generated error message doesn’t include messages created when you enter data incorrectly or ignore system prompts.

Solution: Contact the CMS External User Services Help Desk

The External User Services website has information on common problems and allows you to ask questions, chat live with a support team member, or look up previous support history.

Phone: 1-866-484-8049 (TTY 1-866-523-4759)

Email: [email protected]

EUS Hours of Operation:

• Monday–Friday: 6 am–6 pm CT
• Saturday–Sunday: Closed

Before you log in to PECOS, you need a valid I&A System user ID and password.

Passwords expire every 60 days. The I&A System tells you the number of days until your password expires. If you attempt to log in to PECOS with an expired password, the system redirects you to the I&A System to reset it.

Solution: Access I&A System or Contact I&A System Help

The I&A System website lets you create an I&A System user ID and password, change your password, and recover forgotten login information. You can also access several resources:

• The I&A FAQs helps you resolve common I&A System problems
• The I&A System Quick Reference Guide provides step-by-step instructions, including screenshots, and information about I&A System features and tools

On the I&A System website, select the Help button in the upper right corner of any webpage for more information on that webpage’s topic.

While using PECOS, you may have questions, experience problems enrolling, or need help completing specific PECOS enrollment application sections.

Solution: Contact Your Medicare Enrollment Contractor

Find detailed enrollment contact information in the Medicare Provider Enrollment Contact List . If you have questions, find your MAC’s website .

Solution: Refer to the CMS Provider Enrollment Assistance Guide

If you don’t know who to call for help, refer to the “Who should I call?” CMS Provider Enrollment Assistance Guide .

Find detailed enrollment contact information in the Medicare Provider Enrollment Contact List .

Organizational providers and suppliers must designate a provider enrollment AO to work in CMS systems, including the I&A System , NPPES , and PECOS . The AO may also authorize Access Managers, Surrogates, and SEUs to use PECOS. Individual providers and suppliers don’t require an AO but can authorize Surrogates and SEUs to work in PECOS. Refer to the I&A System Quick Reference Guide and I&A FAQs for more information on registering for an I&A System account or enrolling as an AO.

We use several provider enrollment systems. Specifically, the I&A System allows you to:

• Use PECOS to enroll in Medicare or to update or revalidate your current enrollment information
• Register to get EHR incentive payments for eligible professionals and hospitals that adopt, use and upgrade, or show meaningful use of certified EHR technology

Before completing PECOS enrollment, create an I&A System account. Organizational providers and suppliers must designate an AO to work in these systems.

Use the same information to enroll in Medicare using PECOS as you would for a paper enrollment application.

• If you don’t have an I&A System account, create your username and password
• Use your username and password to log in to NPPES to register for an NPI
• All Medicare provider enrollees must have an active NPI

Based on your provider type, you may also need this information:

• Personal identifying information, including your legal name on file with the Social Security Administration, date of birth, and SSN
• Legal business name of the provider or supplier organization
• Provider or supplier organization’s TIN; if any person or organization has 5% or more partnership interest or ownership (direct or indirect), you must list them on all enrollment records under your TIN
• Professional license information
• School degrees
• Certificates
• W-2 employees and contracted individuals and organizations with managerial control of the provider or supplier
• Accreditation information
• Surety bond information
• Providers self-designate their Medicare specialty on the Medicare enrollment application (CMS 855-I or CMS 855-O) or PECOS when they enroll in the Medicare Program
• Beginning January 1, 2024, we established new provider specialty codes for dentists
• Current medical practice location
• Federal, state, and local (city or county) business and professional licenses, certificates, and registrations specifically required to operate as a health care facility
• Medical record storage information
• Special payment information
• Bank account information
• Suspension, termination, or revocation of a license to provide health care by a state licensing authority or the Medicaid Program
• Conviction of a federal or state felony within 10 years before enrollment, revalidation, or re-enrollment
• Exclusion or debarment from federal or state health care program participation by the Office of Inspector General (OIG) or other federal or state offices with authority to exclude or sanction a provider (or those listed above)

An application is the paper or electronic form you submit for Medicare Program enrollment approval. After the MAC processes the application, PECOS keeps the enrollment record, which includes all your enrollment application data.

You can’t use PECOS to:

• Change your SSN
• Change a provider’s or supplier’s TIN
• Solely owned PA, PC, or LLC can’t be changed to a sole proprietorship
• Sole proprietorship can’t be changed to a PA, a PC, or an LLC

Submit changes noted above using the appropriate paper Medicare enrollment application .

No. All Fee-for-Service (FFS) providers can apply in PECOS.

PECOS is available 24 hours a day, Monday–Saturday, with scheduled downtime on Sunday. We offer technical support daily, 5 am–8 pm CT.

We encourage you to submit your enrollment application through PECOS because it’s faster and easier, but you may complete and mail the appropriate paper Medicare enrollment application to the address on the Medicare Fee-for-Service Provider Enrollment Contact List :

• Parts A and B Providers: Send forms to your Part A or Part B MAC.
• Home Health and Hospice Providers: Send forms to the Home Health and Hospice Contractor.
• DMEPOS Suppliers Send forms to the National Provider Enrollment (NPE) DMEPOS contractor in your region. Find your NPE contractor .

Even if you submit your application on a paper form, your MAC creates an enrollment record in PECOS.

When you electronically submit your Medicare enrollment application, you’ll get a Submission Confirmation page, which will remind you that the individual provider, or the provider or supplier organization AO or Access Manager must electronically sign the application or upload their signature. You’ll be able to see which MAC is processing your application, your unique application tracking number, and real-time information about your application.

PECOS emails the web tracking ID for the submitted application to each address in the Contact Person section of the application. Remember to verify all your completed signatures with either an electronic signature or uploading certification. Mail any required supporting documentation you didn’t upload during submission to the MAC, and include the PECOS tracking ID.

Create a new enrollment:

• If you change your services, like changing specialties
• If you change your location, causing your MAC to need new state surveys and other documentation (your MAC can determine this)
• If you have a change of ownership
• If a provider is creating a new TIN because of a change of ownership
• If you have provider-based vs. freestanding requirements (find your MAC’s website for more information)

Application Fee & Supporting Documentation

Generally, institutional providers and suppliers, like DMEPOS suppliers and opioid treatment programs, pay an application fee when enrolling, re-enrolling, revalidating, or adding a new practice location.

MACs will only process applications with the proper application fee payment or an approved hardship exception.

If you pay the fee during the 30-day period, the MAC processes the application in the usual manner.

No. When you electronically submit the Medicare enrollment application, a page appears that lists the supporting documentation to complete the enrollment. You can submit all this documentation electronically through PECOS.

Yes, either is acceptable. You must send this information electronically (as supporting documentation uploaded into PECOS).

During the PECOS application process, the Penalties for Falsifying Information page has the same text as the paper Medicare enrollment application and lists the consequences for providing false information. These consequences include criminal and civil penalties, fines, civil monetary penalties, exclusion from federal health care programs, and imprisonment, among others. You must acknowledge this page by selecting the Next Page button before continuing the PECOS submission process.

Enrollment Application Issues

First, make sure you entered your correct SSN, legal name, and date of birth. If you believe you entered the correct information but PECOS doesn’t accept this information, contact the Social Security Administration .

You must report an SSN to enroll in Medicare. If you don’t want to report your SSN over the web, use the appropriate paper Medicare enrollment application .

An Invalid Address error indicates the address entered doesn’t comply with the U.S. Postal Service address standards. This page lets you continue by either saving the address you entered or selecting the address PECOS displays.

As a security feature, PECOS will time out if you’re inactive (you don’t hit any keys on your computer keyboard) for 15 minutes. The system warns you of inactivity after 10 minutes. If it gets no response after 5 additional minutes, the system automatically times you out. Save your work if you anticipate inactivity while applying in PECOS. If you don’t save your work and the system times out, you must start from the beginning.

Submitting Reportable Events

No. If you report a change to existing information, check Change , include the effective date of change, and complete the appropriate fields in the impacted sections.

Yes. Following your initial enrollment, report certain changes (reportable events) to your MAC within 30 calendar days of the change. Report all other changes to your MAC within 90 days.

Report a Medicare enrollment change using PECOS. Physicians and NPPs must report a change of ownership or control (including a change in authorized or delegated official), a change in practice location, and any final adverse legal actions (like a felony or suspension of a federal or state license) within 30 days of the change and report all other changes within 90 days of the change.

Since Medicare pays claims by EFT, the Special Payments address should indicate where all other payment information must go (for example, paper remittance notices or special payments).

Providers and suppliers should report most changes using PECOS or the applicable paper Medicare enrollment application .

No. If you have a new business location, complete a new PECOS or paper application. Each DMEPOS enrollment record can only have 1 current business location.

Revalidations

Revalidation means resubmitting and recertifying your enrollment information.

DMEPOS suppliers must revalidate every 3 years, while all other providers and suppliers generally revalidate every 5 years. We can also conduct off-cycle revalidations . You can revalidate using PECOS or by submitting the appropriate paper Medicare enrollment application .

If you’re currently enrolled, check the Medicare Revalidation List to find your revalidation due date. If you see a due date, submit your revalidation before that date. Your MAC will also send you a revalidation notice.

Due dates are:

• Updated in the Medicare Revalidation List every 60 days at the beginning of the month
• Listed up to 7 months in advance or listed as to be determined (TBD) if the due date is more than 7 months away

Yes. Your MAC will send a revalidation notice 90–120 days before your revalidation due date.

If there’s no due date listed on the Medicare Revalidation List or you didn’t get a MAC letter requesting revalidation, don’t submit your revalidation application. Your MAC will return it to you.

However, if you’re within 2 months of the due date listed on the Medicare Revalidation List and didn’t get a MAC notice to revalidate, submit your revalidation application.

Yes. PECOS lets you review information on file and update and electronically submit your revalidation. If you use PECOS, you need to update only changed information.

If you submit your revalidation after its due date, your MAC may place a hold on your Medicare payments or deactivate your Medicare billing privileges. If the MAC requests additional documentation, respond within 30 days. If you don’t, they may deactivate your Medicare billing privileges.

Revalidation ensures all provider enrollment records are accurate and current. Generally, we don’t take administrative action against a provider or supplier for updating their records even though it wasn’t timely. However, we could take administrative actions, including recovering previous Medicare payments, when a provider or supplier that fails to report the change causes their Medicare enrollment to become ineligible.

PECOS users can’t mail documents that require a signature. When submitting your application, be prepared to send an e-signature or upload your signed documents.

Protect Your Identity & Privacy

You can help protect your professional medical identifiers from identity thieves attempting to defraud the Medicare Program.

Keep PECOS Enrollment Information Current

Log in to PECOS and review your Medicare enrollment information several times a year to ensure no unauthorized changes were made.

PECOS Provides Security

Only you, authorized surrogates, authorized CMS officials, and MACs may enter and view your Medicare PECOS enrollment information. CMS officials and MACs get security standards training and must protect your information. We don’t disclose your Medicare enrollment information to anyone, except when authorized or required by law.

Review & Protect Enrollment Information

Review your Medicare enrollment information in PECOS frequently to ensure it’s accurate, current, and unaltered.

Use your I&A System user ID and password to access PECOS. Keep your ID and password secure.

Protect Yourself & CMS Programs from Fraud

Your NPI and TIN are publicly available information. Use extra caution to monitor and protect your professional and personal information to help prevent fraud and abuse. Also ensure your patients’ personal health information is secure. Refer to these resources:

• Medicare Fraud & Abuse: Prevent, Detect, Report
• Office of Inspector General
• Reporting Medicare fraud & abuse

Take these steps to verify your Medicare enrollment information:

If you suspect your PECOS profile is incorrect due to unauthorized account access, contact your MAC, law enforcement authorities, and your bank. Your MAC and bank can flag your respective accounts for possible fraudulent activity, and law enforcement can begin investigating if and how your accounts were compromised.

Additional Privacy Tips

Take these additional actions to protect your Medicare enrollment information:

• Change your password in the I&A System before accessing PECOS the first time. You can’t change your user ID, but you must change your password every 60 days.
• Review your Medicare enrollment information several times a year to ensure no one changed information without your knowledge. Immediately report changes you didn’t submit.
• Maintain your Medicare enrollment record. Report Medicare enrollment changes known as reportable events, including change of ownership or control , change in practice location, banking arrangements, and any final adverse legal actions.
• Store PECOS copies or paper enrollment applications in a secure location. Don’t allow others access to this information as it contains your personal information, including your date of birth and SSN. Don’t leave copies in a public workspace.
• Enroll in electronic Medicare payments, and ensure they deposit directly into your bank account. We require all providers to use electronic funds transfer (EFT) when enrolling in Medicare, revalidating, or making changes to their enrollment. The most efficient way to enroll in EFT is to complete the EFT information section in PECOS and provide the required supporting documentation. Using EFT allows us to send payments directly to your bank account.

DMEPOS Supplier Requirements

Dmepos supplier standards, accreditation, & surety bond.

To enroll or keep your Medicare billing privileges, all DMEPOS suppliers (except certain exempted professionals) must meet supplier and DMEPOS Quality Standards to become accredited. Certain DMEPOS suppliers must also submit a surety bond .

DMEPOS suppliers (except those exempted eligible professionals and other persons) must be accredited by a CMS-approved accrediting organization before submitting a Medicare enrollment application to the National Provider Enrollment (NPE) DMEPOS contractors .

Each enrolled DMEPOS supplier covered under the Health Insurance Portability and Accountability Act (HIPAA) must name each practice location (if it has more than 1) as a sub-part and make sure each sub-part gets its own NPI.

Individual DMEPOS Suppliers (for example, sole proprietorships)

Physicians, NPPs, and DMEPOS suppliers may use their I&A System user ID and password to access PECOS . If you don’t already have an I&A System account, refer to the I&A System User Registration page and enter the information to open an account. For help, refer to the How to Setup Your Account if you are a Sole Owner section in the I&A System Quick Reference Guide .

As an individual DMEPOS supplier, you don’t need an AO or another authorized user.

Organizational DMEPOS Suppliers System Users

A DMEPOS supplier organization must appoint an AO to manage connections and staff, including appointing and approving other authorized PECOS users. The organization must identify the AO in the enrollment application. The AO must have ownership or managing control in the DMEPOS supplier organization.

Providers Who Solely Order or Certify

Physicians and other eligible professionals must enroll in the Medicare Program or have a valid opt-out affidavit on file to solely order or certify Medicare patient items or services.

Those physicians and other eligible professionals enrolled solely as ordering/certifying providers don’t send billed service claims to a MAC.

Ordering/Certifying Terms

Part B claims use the term ordering/certifying provider to identify the professional who orders or certifies an item or service reported in a claim. These are technically correct terms:

• Providers order non-physician patient items or services, like DMEPOS, clinical lab services, or imaging services
• Providers certify patient home health services

The health care industry uses the terms ordered , referred , and certified interchangeably .

Who Are Eligible Ordering/Certifying Providers?

Physicians or eligible professionals who order or certify Part A or Part B services but don’t want to submit Medicare claims are eligible ordering/certifying providers.

A person already enrolled as a Part B provider may submit claims listing themselves as the ordering/certifying provider without re-enrolling using Medicare Enrollment Application: Enrollment for Eligible Ordering/Certifying Physicians and Other Eligible Professionals (CMS-855O) .

Note: Those who enroll as eligible providers using CMS-855O can’t bill Medicare, and we can’t pay for their services because they have no Medicare billing privileges.

Organizational NPIs don’t qualify, and you can’t use them to order or certify.

Eligible providers must meet these basic conditions:

• Have an individual NPI
• Be enrolled in Medicare in either an approved or opt-out status
• Be an eligible specialty type to order or certify

Denial of Ordering/Certifying Claims

If claims lack a valid individual NPI, MACs deny them if they’re from:

• Clinical labs for ordered tests
• Imaging centers for ordered imaging procedures
• DMEPOS suppliers for ordered DMEPOS
• Part A home health agencies that aren’t ordered or certified by a Doctor of Medicine, Osteopathy, or Podiatric Medicine

If you bill a service that needs an eligible provider and they aren’t on the claim, the MAC will deny the claim. The claim must have a valid NPI and the eligible provider’s name as it appears in PECOS.

If a provider who’s on the Preclusion List prescribes a Medicare Part D drug, drug plans will deny it.

Requirement 1: Get an Individual NPI

The 2 types of NPIs are: Type 1 (individual) and Type 2 (organizational). Medicare allows only Type 1 NPIs to solely order items or certify services. Apply for an NPI through:

• Online Application: Get an I&A System user account. Then apply for an NPI in NPPES .

Requirement 2: Enroll in Medicare in an Approved or Opt-Out Status

Once you have an NPI, use PECOS to verify current Medicare enrollment record information, including your NPI and that you’re approved, or go to the Opt Out Affidavits list to check your status. To opt out of Medicare, submit an affidavit expressing your decision to opt out of the program.

Part C and Part D providers don’t have to enroll in Medicare in an approved or opt-out status.

*We deny certain power mobility device claims if the ordering provider isn’t on our eligible providers list.

Requirement 3: Be Eligible to Order or Certify

The physicians and eligible professionals who may enroll in Medicare solely for ordering or certifying include, but aren’t limited to, physicians and eligible professionals who are:

• Department of Veterans Affairs employees
• Public Health Service employees
• Department of Defense or TRICARE employees
• Indian Health Service or Tribal Organization employees
• Federally Qualified Health Center, Rural Health Clinic, or Critical Access Hospital employees
• Licensed Residents in an approved medical residency program defined in 42 CFR 413.75(b)
• Dentists, including oral surgeons
• Pediatricians
• Retired, licensed physicians

If you’re unsure whether your specific provider specialty qualifies to enroll as an ordering/certifying provider, refer to Section 4 of CMS-855O or find your MAC’s website before submitting a Medicare enrollment application.

Interns & Residents

Claims for items or services ordered or certified by licensed or unlicensed interns and residents must specify a teaching physician’s NPI and name. State-licensed residents may enroll to order or certify and can be listed on claims. If states offer provisional licenses or otherwise permit residents to order/certify, we allow interns and residents to enroll consistent with state law.

Requirement 4: Respond to Requests for More Information

• To see your enrollment status without logging in, go to PECOS and, under Helpful Links , select Application Status .

Requirement 5: Use PECOS to Keep Enrollment Information Current

Report a Medicare enrollment change using PECOS. Providers and suppliers must report a change of ownership or control (including a change in authorized or delegated official), a change in practice location, and any final adverse legal actions (like revocation or suspension of a federal or state license) within 30 days of the change and must report all other changes within 90 days of the change.

Revalidation

Revalidation, or re-submitting and recertifying your enrollment information accuracy, is an important anti-fraud tool. All Medicare-enrolled providers and suppliers must periodically revalidate their enrollment information .

Generally, physicians, including physician organizations, opioid treatment programs, Medicare Diabetes Prevention Program suppliers, and institutional providers, revalidate enrollment every 5 years or when we request it. DMEPOS suppliers must revalidate their enrollment information every 3 years.

PECOS is the most efficient way to revalidate information.

If you’re actively enrolled, go to the Medicare Revalidation List to find your revalidation due date. If you see a due date, submit your revalidation before that date. Your MAC notifies you when it’s time to revalidate. If you submit your revalidation application after the due date, your MAC may hold your Medicare payments or deactivate your billing privileges.

Rebuttal Process

MACs issue Medicare billing privilege deactivations. We permit providers and suppliers to file a rebuttal .

Get more information:

• 42 CFR 424.515
• Provider Enrollment Revalidation Cycle 2 FAQs
• Revalidations (Renewing Your Enrollment)

Large Group Coordination

Groups with more than 200 members can use the Medicare Revalidation List and search by their organization’s name to download group information. Their MAC will send them a letter and spreadsheet that lists the providers linked to their group who must revalidate within 6 months. Large groups should work together to ensure they submit only 1 application from each provider or supplier.

Use these resources to learn how to enroll in the Medicare Program, revalidate your enrollment, or change your enrollment information. Enroll in the Medicare Program to get paid for providing covered patient services. Enroll if you solely order items or certify services.

You can enroll online by using PECOS or the appropriate paper enrollment application you submit to your MAC.

• Get an I&A System user account
• Apply for your NPI in the NPPES
• Enroll in PECOS

Enrollment Forms

If you enroll using a paper application instead of PECOS , search the CMS Forms List to find the form you need and read on page 1, Who Should Submit This Application .

Commonly Used Terms

View the Medicare Learning Network® Content Disclaimer and Department of Health & Human Services Disclosure .

The Medicare Learning Network®, MLN Connects®, and MLN Matters® are registered trademarks of the U.S. Department of Health & Human Services (HHS).

Medicare Provider Enrollment – Site Verification

by nCred | Medicare Provider Enrollment | 0 comments

Medicare Provider Enrollment News

CMS contracts with a third party to provide site visit services as an integral part of the Medicare Provider Enrollment process.  The National Sive Visit Contractor (NSVC) will conduct site visits for all providers and suppliers except for Durable Medical Equipment (DMEPOS) which will continue to be inspected by the National Supplier Clearinghouse.  MSM Security Services, LLC has the national site visit contract.  MSM, or one of its subcontractors, will conduct a site verification and screening process according to Medicare guidelines to prevent questionable providers and suppliers from enrolling in the Medicare program.  When an inspector shows up, he or she will have valid ID and a letter of authorization to begin the inspection.  You may not copy or retain the ID or letter of authorization.  You may contact MSM at any point if you have questions at 855-220-1074.

The site verification may be as quick as verifying your business location, or an inspector may physically show up to tour your clinic.  The process ensures that providers aren’t able to Enroll as participating Medicare providers without an appropriate service location.

You may see full details in section 10.6.20 of the Medicare Program Integrity Manual .

Call nCred today at (423) 443-4525 to discuss your Medicare Provider Enrollment needs.  We work with all specialties and have extensive experience processing Medicare applications.

From the Medicare Program Integrity Manual:

10.6.20 – Screening: On-site Inspections and Site Verifications (Rev. 11949; Issued: 04-13-23; Effective: 04-21-23; Implementation: 06-19-23) 

The contractor shall review section 10.3 of this chapter for special instructions regarding site visits. In the event of a conflict, those instructions take precedence over those in this section 10.6.20.

A. DMEPOS Suppliers and IDTFs

The scope of site visits of DMEPOS suppliers and IDTFs shall continue to be conducted in accordance with existing CMS instructions and guidance. (For purposes of this section 10.6.20, the term “contractor” refers to the Medicare Administrative Contractor; the term “SVC” refers to the site visit contractor.)

B. Provider and Supplier Types Other Than DMEPOS Suppliers and IDTFs

For provider/supplier types other than DMEPOS suppliers and IDTFs – that must undergo a site visit pursuant to this section 10.6.20 and § 424.518, the SVC will perform such visits consistent with the procedures in this section 10.6.20. This includes all of the following:

(1) Documenting the date and time of the visit, and including the name of the individual attempting the visit.

(2) Photographing the provider/supplier’s business for inclusion in the provider/supplier’s file. All photographs will be date/time stamped.

(3) Fully documenting observations made at the facility, which could include facts such as (a) the facility was vacant and free of all furniture, (b) a notice of eviction or similar documentation is posted at the facility, and (c) the space is now occupied by another company.

(4) Writing a report of the findings regarding each site verification.

(5) Including a signed site visit report stating the facts and verifying the completion of the site verification.

In terms of the extent of the visit, the SVC will determine whether the following criteria are met: (i) the facility is open; (ii) personnel are at the facility; (iii) customers are at the facility (if applicable to that provider or supplier type); and (iv) the facility appears to be operational. This will require the site visitor(s) to enter the provider/supplier’s practice location/site rather than simply conducting an external review. If any of the four elements ((i) through (iv)) listed above are not met, the contractor will, as applicable – and using the procedures outlined in this chapter and in existing CMS instructions – deny the provider’s enrollment application pursuant to § 424.530(a)(5)(i) or (ii) or revoke the provider’s Medicare billing privileges under § 424.535(a)(5)(i) or (ii).

C. Operational Status

When conducting a site verification to determine whether a practice location is operational, the SVC shall make every effort to limit its verification to an external review of the location. If the SVC cannot determine whether the location is operational based on this external review, it shall conduct an unobtrusive site verification by limiting its encounter with provider or supplier personnel or medical patients.

The contractor must review and evaluate the site visit results received from the SVC prior to making a final determination. If it is determined (during the review and evaluation process) that the location is non-operational based on the site visit results but there is reason to proceed with the enrollment, the contractor shall provide the appropriate justification in the comment section of the Validation Checklist in PECOS. (For example, a second site visit determined the location to be operational; the provider only renders services in patient’s homes; etc.).

If the contractor is unsure of how to proceed based on its evaluation of the site visit results, it shall contact its PEOG BFL and copy its contracting officer’s representative (COR).

Site verifications should be done Monday through Friday (excluding holidays) during their posted business hours. If there are no hours posted, the site verification should occur between 9 a.m. and 5 p.m. If, during the first attempt, there are obvious signs that the facility is no longer operational, no second attempt is required. If, on the first attempt, the facility is closed but there are no obvious indications that the facility is non-operational, a second attempt on a different day during the posted hours of operation should be made.

E. Documentation

As indicated previously, when conducting site verifications to determine whether a practice location is operational, the SVC shall:

(i) Document the date and time of the attempted visit and include the name of the individual attempting the visit.

(ii) As appropriate, photograph the provider/supplier’s business for inclusion in the provider/supplier’s file on an as-needed basis. All photographs should be date/time stamped.

(iii) Fully document all observations made at the facility (e.g., the facility was vacant and free of all furniture, a notice of eviction or similar documentation was posted at the facility, the space is now occupied by another company, etc.).

(iv) Write a report of its findings regarding each site verification.

F. Determination

(In the event an instruction in this subsection F is inconsistent with guidance in section 10.6.6, 10.4.7 et seq., or 10.4.8, the latter three sections of instructions shall take precedence.)

If a provider/supplier is determined not to be operational or in compliance with the regulatory requirements for its provider/supplier type, the contractor shall revoke the provider/supplier’s Medicare billing privileges – unless the provider/supplier has submitted a change of information request that notified the contractor of a change in practice location. Within 7 calendar days of CMS or the contractor determining that the provider/supplier is not operational, the contractor shall update PECOS or the applicable claims processing system (if the provider/supplier does not have an enrollment record in PECOS) to revoke Medicare billing privileges and issue a revocation notice to the provider/supplier. The contractor shall afford the provider/supplier applicable appeal rights in the revocation notification letter.

For non-operational status revocations , the contractor shall use either 42 CFR § 424.535(a)(5)(i) or 42 CFR § 424.535(a)(5)(ii) as the legal basis for revocation. Consistent with 42 CFR § 424.535(g), the date of revocation is the date on which CMS or the contractor determines that the provider/supplier is no longer operational. The contractor shall establish a 2-year reenrollment bar for providers/suppliers that are not operational.

For regulatory non-compliance revocations , the contractor shall use 42 CFR § 424.535(a)(1) as the legal basis for revocation. Consistent with 42 CFR § 424.535(g), the date of revocation is the date on which CMS or the contractor determines that the provider/supplier is no longer in compliance with regulatory provisions for its provider/supplier type. The contractor shall establish a 2-year enrollment bar for providers/suppliers that are not in compliance with provisions for their provider/supplier type.

G. Multiple Site Visits

Notwithstanding any other instruction to the contrary in this chapter, the contractor shall not order a site visit if the specific location to be visited has already undergone a successful site visit within the last 12 months and the applicable provider/supplier is in an approved status.

Consider the following illustrations:

Example 1  – A single-site home health agency (HHA) undergoes a revalidation site visit on February 1. The HHA submits a change of information request on July 1 to add a branch location. The contractor shall order this site visit because the visit will occur at a location (i.e., the branch location) different from the main location (i.e., the location that underwent the February 1 revalidation visit).

Example 2  – A DMEPOS supplier undergoes a revalidation site visit on April 1. It submits an initial Form CMS-855S application on May 1 to enroll a second location. The new location shall undergo a site visit because: (1) it is different from the first (revalidated) location; and (2) it is/will be separately enrolled from the first location.

Example 3  – A physical therapy (PT) group has three locations – X, Y, and Z. As part of a revalidation, the contractor elects to order a site visit of Location Y rather than X or Z. The visit was performed on June 1. On October 4, the group submits a Form CMS-855B to report a change of ownership, thus requiring a site visit under this chapter. However, the contractor shall not order a visit for Location Y because this site has been visited within the past 12 months. Location X or Location Z must instead be visited.

Example 4  – An IDTF undergoes an initial enrollment site visit on July 1. On September 24, it submits a Form CMS-855B application to change its practice location; this mandates a site visit under this chapter. The site visit shall be performed even though the initial visit took place within the past 12 months. This is because the second visit will be of the new location, whereas the first visit was of the old location.

H. Certified Providers/Suppliers – Address Validation Error

Notwithstanding any other instruction to the contrary in this chapter, the contractor need not order a site visit for a certified provider/supplier prior to making a recommendation to the state if an address validation error is received in PECOS. The contractor shall override the error message and notate in the referral package that the address was unverifiable. This avoids multiple site visits being performed (that is, pre-enrollment, survey, and post enrollment).

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Medicaid Providers are Subject to Post-Enrollment Site Visits

By marissa machado posted jun 12,2017 12:38 pm.

As part of Federal Regulation (Code of Federal Regulations 455.432), Texas Medicaid & Healthcare Partnerships (TMHP) may conduct a scheduled or unscheduled post-enrollment site visit for providers who are designated as “moderate” or “high” risk. The purpose of a post-enrollment site visit is to verify that providers are in compliance with federal and state enrollment requirements. 

During the unscheduled and unannounced pre-enrollment site visits, an audit will be performed to ensure that prospective providers meet enrollment requirements. During post-enrollment site visits, an audit will be performed to ensure that current providers remain operational and continue to meet required provider standards. Failure to comply may result in denial and or termination of a provider’s Medicaid contract. 

For more information about Affordable Care Act Provider Enrollment, providers can refer to the Affordable Care Act (ACA) Provider Enrollment Frequently Asked Questions (FAQ) document. 

For more information, call the TMHP Contact Center at 1-800-925-9126.

Texas Association for Home Care and Hospice

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FAC Number: 2024-05 Effective Date: 05/22/2024

52.237-1 Site Visit.

As prescribed in 37.110 (a) , insert the following provision:

Site Visit (Apr 1984)

Offerors or quoters are urged and expected to inspect the site where services are to be performed and to satisfy themselves regarding all general and local conditions that may affect the cost of contract performance, to the extent that the information is reasonably obtainable. In no event shall failure to inspect the site constitute grounds for a claim after contract award.

(End of provision)

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Pre-Bid Meetings and Site Visits

• Jorge A. Lynch T.

Pre-bid meetings are usually held, if previously mentioned in the solicitation documents , during the bid / proposal preparation period. Their purpose is to clarify any concerns bidders may have with the solicitation documents , scope of work and other details of the requirement. These meetings are formal and the results are made available in writing to all prospective bidders that registered interest in the requirement, be it through requesting, buying or downloading the solicitation documents from an official website. Prospective bidders are permitted to request clarifications by a date and time stipulated in the solicitation documents .

It is most beneficial to hold pre-bid meetings prior to formally responding to the request for clarifications, that way the responses to the request for clarifications can be sent along with the results of the pre-bid meeting , including a copy of the minutes of the pre-bid meeting .

Although prospective bidders should be encouraged to get as much information as possible (including visiting the site) on a specific or upcoming requirement of a procuring entity , formal site visits are usually planned and carried out for works procurement and more complex goods requirements southafrica-ed.com .

When a site visit is planned, the details of the date and time must be stated in the solicitation documents . And the site visit should take place before (but not too far in advance of) the pre-bid meeting . The results are also formally sent to all prospective bidders that expressed interest in the requirement, by way of minutes of the site visit and pre-bid meeting , including consolidated responses to request for clarifications, also from prospective bidders.

The pre-bid meeting is usually open to all interested prospective bidders; however, in cases where pre-qualification or short-listing is carried out, only pre-qualified or short-listed bidders are invited to attend the pre-bid meeting .

Site visits, as mentioned above, can and should preferable be held prior to the pre-bid meeting . The reason for this preference is because after the site visit, bidders may have additional queries and these can be addressed at the pre-bid meeting and formally sent (with the minutes) to all prospective bidders that expressed interest in the requirement, or those that were short-listed through a pre-qualification exercise or restricted bidding process. The time and venue of these meetings are addressed in the solicitation documents , and attendance is usually not obligatory.

During the site visit the prospective bidders survey the site and ask questions to clarify any doubts or information provided in the solicitation documents . Sometimes, as a result of the site visit/ pre-bid meeting there might be a need to extend the bid / proposal submission date by way of Addendum to the solicitation documents to give bidders sufficient time to address any changes made to the solicitation documents as a result of the site visit and/or pre-bid meeting .

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4 thoughts on “pre-bid meetings and site visits”.

can the site visit be in different times/ i belive no to keep all bidders expose to same info and not to miss any thing

what do you think

I agree with you Salem. In theory, the site visit could be at different time, and we should permit potential bidders to visit the site during the bid submission period. But, for practical purposes, it should be conducted in an organized manner and whatever is discussed must be put in writing and formally sent to all bidders that registered interest in the procurement.

What do you think?

I am interested in finding out how many days, before a scheduled pre-bid meeting (or bid document release date) should the legal notice be advertised in the paper?

Ideally, you want to give prospective bidders sufficient time to get familiar with the content of the bidding documents so they can prepare their questions and seek clarification either before or during the pre-bid meeting. At least 5 days after publication of the procurement notice is sufficient. Ten days is even better for more complex procurements.

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Public Procurement and Contract Administration: A Brief Introduction

This book gives you a brief introduction to public procurement and contract administration . It covers the public procurement cycle; procurement planning; requesting, receiving and evaluating bids and proposals; contract negotiations and award; and contract administration (from commencement to close-out). A glossary of terms used in the text is also included, with suggestions for further reading.

Frequently Asked Questions on Public Procurement: A Reference Guide to Procurement and Contract Administration Basics

An introductory text on public procurement and contract administration ; this book walks you through the public procurement process in a question and answer format, from procurement planning through contract administration and management. A glossary of terms used in the text is also included, as well as suggestions for further reading.

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• Site Visit Protocols and Guides
• Health Center Program Site Visit Protocol

Introduction

In this section :

Site Visit Report and Compliance Determinations

Site visit protocol structure.

The purpose of Health Resources and Services Administration (HRSA) site visits 1  is to support effective monitoring of the Health Center Program. Operational Site Visits (OSVs) provide an objective assessment to verify the status of each Health Center Program awardee or look-alike’s compliance with the statutory and regulatory requirements of the Health Center Program. In addition, HRSA conducts site visits to assess and verify the eligibility and compliance of look-alike initial designation applicants for initial designation determinations. For the purposes of this document, the term “health center” refers to entities that apply for or receive a federal award under section 330 of the Public Health Service (PHS) Act (including section 330 (e), (g), (h) and (i)), section 330 subrecipients, and organizations designated as look-alikes.

HRSA uses the Health Center Program Compliance Manual (“Compliance Manual”) to determine whether health centers have demonstrated compliance with the statutory and regulatory requirements of the Health Center Program. The Health Center Program Site Visit Protocol (SVP) is based on the Compliance Manual and is the tool for assessing compliance with Health Center Program requirements during OSVs and look-alike initial designation (ID) site visits. The SVP uses standard and transparent methodologies to provide HRSA with information to monitor health center compliance. The SVP also includes a section to document promising practices.

During a site visit, at the health center’s request, the site visit team may share recommendations or limited technical assistance on areas of health center operations that are outside the scope of the compliance review. Such recommendations or technical assistance information will not be included in the final site visit report.

HRSA conducts OSVs at least once per period of performance. For health centers with a 1-year period of performance, the OSV will take place 2-4 months into the period of performance. For health centers with a 3-year period of performance, the OSV will take place 12–16 months into the period of performance.

Health centers should use the Compliance Manual, the SVP, and other site visit resources to prepare for site visits and to regularly assess and ensure ongoing compliance with the Health Center Program. 

For answers to frequently asked questions (FAQs) and resources to help health centers prepare for site visits, visit Site Visit Resources .

HRSA shares the site visit report with the health center within 45 days after the visit. The report conveys the site visit findings and final compliance determinations. In circumstances where HRSA determines that a health center has failed to demonstrate compliance with one or more of the Health Center Program requirements, HRSA will place one or more conditions on the health center’s award or designation. 2

The Federal Tort Claims Act (FTCA) Program also uses the site visit report to support FTCA deeming decisions and to identify technical assistance needs for FTCA-deemed health centers. Unresolved Health Center Program conditions related to clinical staffing and/or quality improvement/assurance requirements that apply to both Health Center Program and FTCA deeming, may impact FTCA deeming if they are not resolved by the time that HRSA makes annual FTCA deeming decisions. Health centers that have questions about the FTCA Program or FTCA deeming requirements may use the BPHC Contact Form or call 1–877–464–4772 .

Health centers and look-alike initial designation applicants should review the site visit report and the Compliance Manual for guidance on resolving non-compliance findings 3 , and may contact their assigned HRSA Program Specialist or use the BPHC Contact Form for additional information or assistance. 

Each Compliance Manual chapter that addresses Health Center Program requirements has a corresponding section in the SVP. The SVP also includes a section on the FTCA Program risk management and claims management requirements.

Each section of the SVP is structured as follows:

• Statute and Regulations: The supporting statute and regulations for the associated program requirements. There also is a link to the Related Considerations in the Compliance Manual.
• Primary and Secondary Reviewers: The member of the site visit team who serves as the primary reviewer for that SVP section, based on expertise (governance/administrative, fiscal, or clinical), and a suggested secondary reviewer who may add expertise and assistance as needed. The site visit team collaborates on compliance assessments.
• When the SVP allows for a range in the sample size, the health center should take into account its size and complexity when determining sample size.
• The health center should provide samples that are representative of its current Health Center Program project operations.
• If the HRSA site visit team is unable to assess the program requirement using the health center’s sample, the team may complete additional sampling in coordination with the health center.
• “ Form 5A: Services Provided (PDF - 158 KB) ” abbreviated as “Form 5A.”
• “ Form 5B: Service Sites (PDF - 171 KB) ” abbreviated as “Form 5B.”
• "Column I, Direct (Health Center Pays)" abbreviated as “Column I.”
• “Column II, Formal Written Contract/Agreement (Health Center Pays)” abbreviated as “Column II.”
• “Column III, Formal Written Referral Arrangement (Health Center Does NOT Pay)” abbreviated as “Column III.”
• Documents not provided by the close of the first day of the site visit will not be considered in the compliance assessment by the site visit team. 
• Demonstrating Compliance Elements: Elements from the Compliance Manual that describe how health centers would demonstrate their compliance with the applicable Health Center Program requirements. 6
• Site Visit Team Methodology: Methods the site visit team uses to assess compliance. Methods include but are not limited to reviews of policies and procedures, samples of files and records, site tours, and interviews. 7 All documentation provided to the site visit team, whether by HRSA or by the health center, are available to the entire site visit team and can be used for any portion of the site visit.
• Site Visit Findings: Questions, based on the related methodologies, answered by the site visit team to document its compliance assessment. HRSA uses these responses, which are included in the health center’s site visit report, to determine the health center’s compliance with Health Center Program requirements.

1. The U.S. Department of Health and Human Services (HHS) Uniform Administrative Requirements (45 CFR 75.342) permit HRSA to “make site visits, as warranted by program needs.” In addition, 45 CFR 75.364 states that, “The HHS awarding agency, Inspectors General, the Comptroller General of the United States, and the pass-through entity, or any of their authorized representatives, must have the right of access to any documents, papers, or other records of the non-federal entity which are pertinent to the federal award, in order to make audits, examinations, excerpts, and transcripts. The right also includes timely and reasonable access to the non-federal entity's personnel for the purpose of interview and discussion related to such documents.”

2. For additional information on how HRSA pursues remedies for non-compliance, including progressive action, see Health Center Program Compliance Manual, Chapter 2: Health Center Program Oversight .

3. Look-alike initial designation applicants must be compliant with all Health Center Program requirements at the time of application and should refer to the look-alike Initial Designation application for further guidance on how HRSA will address findings of non-compliance at a pre-designation OSV.

4. Site visit teams, including consultants, are authorized representatives of HRSA and thus may review a health center’s policies and procedures, financial or clinical records, and other relevant documents, in order to assess and verify compliance with Health Center Program and FTCA deeming requirements. Site visit teams are also subject to confidentiality standards, including Health Insurance Portability and Accountability Act (HIPAA). Consultants who violate such standards are in violation of their contract, and could be subject to Title 18, United States Code, Section 641. While it is permissible for health centers to request that HRSA staff and consultants sign additional confidentiality statements, this should be communicated to HRSA and the site visit team before the site visit to avoid any disruption or delay in the site visit process.

5. Health centers may choose to provide samples of patient records before or during the site visit. If patient records will be provided during the site visit, this should be communicated to the site visit team before the site visit to avoid any disruption or delay in the site visit process.

6. A small subset of elements are not assessed during a site visit because HRSA assesses them by other means (for example, competitive application review, look-alike Renewal Designation application review, HRSA Division of Grants Management Office (DGMO) review).

7. Interviews with health center staff are intended to supplement and assist the site visit team in its review of policies, procedures, and other documentation.

Free Site Analysis Checklist

Every design project begins with site analysis … start it with confidence for free!

Site Visit Analysis and Report: How to conduct and evaluate your first architecture site visit

• Updated: January 2, 2024

Here we will cover everything you need to know about of how to approach your first site visit analysis for a new project, what to do when physically there, and how to eventuate and summarize the information you collect.

However before visiting for the first time we highly recommend that you carry out desktop study beforehand, as this will provide an important initial understanding of the site and generate far better results and more refined questions once there.

The desktop study will also help to identify the important items of equipment that you will need to take with you to make your trip as successful as possible. …these are mentioned below but may include a: 

• Site map (very important)
• Tape measure
• Laser distance meter

…more essential architects items here

Conducting an architecture site visit analysis

A site visit analysis is a comprehensive report that summarizes the findings of a physical inspection of a potential development site. It includes information on the site’s physical characteristics, location, surrounding area, demographic information, environmental impact, zoning regulations, traffic flow, and recommendations for development.

The report synthesizes all gathered information to provide a comprehensive understanding of the site and its potential.

What to look for?

Once there, there are a whole number of important areas and items that need to be studied and recorded, some of which would have already been identified during your desktop study, but as a starting point we’ve produced the below list of all the key areas:

We suggest that you take these with you and tick them off as they are found, so not to miss anything.

• Entrance and access points (both pedestrian and vehicle)
• Security (gates, surveillance)
• Travelling to the site (road types and suitability, safety, public transport)
• Boundary treatment (fencing, vegetation, land form, water)
• Extent of boundary (does it match the survey/OS map)
• Circulation (existing travel routes within the site)
• Noise levels (quiet and loud areas)
• Services (electric, gas, water, sewage)
• Existing buildings (condition? Relevant? Protected?)
• Existing landscape features (condition? Relevant? Protected?)
• Neighbouring buildings (local vernacular, protected?)
• Views in and out of the site (areas to screen off and areas to draw attention to)
• Tree’s and vegetation (protected and rare species)
• Ecology (any areas likely to be home to protected species)
• Orientation (sun and wind paths)
• Light levels (areas in direct sunlight, shaded areas, dappled light)
• Accessibility (disability access)
• Surrounding context (historical, heritage, conservation area, SSSI, AONB)
• Existing materials in and around the site
• Topography (site levels)
• Flood level (is it likely to flood)
• Soil and ground conditions (types and suitability)
• Existing legal agreements (where are the rights of way, covenants)
• Hazards (Electricity lines, Drainage, Telephone lines, Sub-stations)

We provide a site analysis checklist here covering all of the above that’s free to download.

Where to start

You want to begin documenting your visit as soon as you arrive, as the approach and entrance to your site are just as important as the site itself. If you’re desktop study didn’t highlight the possible routes and methods of transport to and from the site, then this needs to be recorded also.

Documenting your first impressions is vitally important, ask yourself; what do you see as you enter the site? what do you hear? what do you feel? (…what senses are the first to be triggered), you will only get one chance to do this properly and so you need to make it count!

…and don’t forget to include the location of the elements you record, when noting it down on your site map or survey. By the end of your visit, you should barley be able to read whats under all your notes …write down everything!

Moving on from first impressions, you should plan to walk around the site as least twice (as a minimum) to ensure that nothing is missed, so leave enough time to make a least two loops, noting down and photographing everything that you feel is relevant, no matter how small.

…there’s nothing worse than getting back to the studio and realizing you forgot to document something.

We like to use the check list supplied above and:

• Firstly walk around the site whilst annotating a site plan
• Secondly with a camera …photographing everything
• and thirdly with both …just in case something has been missed

This way we can focus on one task at a time, helping to ensure we gather everything we need.

In terms of a camera, and depending on your budget we suggest looking one these three options (but a phone is just as good):

• Sony DSCW800 Digital Compact Camera
• Sony DSCWX350 Digital Compact Camera
• Canon EOS 1300D DSLR Camera

It can be difficult to identify certain elements, and some may only be noticeable from a professional survey, such as underground services and precise spot levels. But approximations of such locations and heights are a good start and can serve as a reminder for further investigation.

If accessible you can of course take your own measurements and so this is where a tape measure and/or distance meter will come in handy.

Try one of these:

–  Tape measure

– Laser distance meter

What to take with you

Firstly look at the weather, you wont have a good time if your not dressed appropriately, and this applies to protecting your notes and equipment as well as yourself.

…a simple quick check, can make or break a visit, arranging to go on sunny day will also give you the best site photographs, which could also be used in future CGI’s and presentation material. 

If the site is derelict, or has potentially dangerous or hazardous elements, it is likely that you will require personal protection equipment (otherwise known as PPE) so make sure this is organised before setting off.

As a minimum you want to take with you a camera, a pen and an OS map. Google Maps can provide a temporary (though very basic) version, but a much preferred scaled version that can normally be obtained through your university or practice via such companies as:

• Digimap – digimap.edina.ac.uk
• Xero CAD – xerocad.co.uk
• CAD Mapper – cadm a pper.com (free account available)

As mentioned, you will want to make notes, and record everything you observe, experience and hear all over this map. So print out a couple of copies at a usable and convenient size.

A camera is essential in documenting the site, and the pictures taken during your visit are likely to be used on a daily basis throughout your project. So once again make sure you document and record everything.

Pictures should be taken from all distances, close zoomed-in sections of materials and textures along with shots of the site from a distance to include the area as a whole and within its context.

Note pads are important for obvious reasons, we prefer an A5 sized pad, as this is much easier to carry and hold than an A4 one.

Tape measures can be useful, but we never go on a site visit without a distance meter.

…and lastly if you’re visiting on your own, don’t forget to tell someone where you’ll be and take your phone with a charged battery.

Our site visit equipment check list looks something like this:

• Weather check
• Print out our “what to look for” checklist
• Site map (at least 2 copies)
• PPE equipment
• Scale ruler

If you are interested in trying our architecture site analysis symbols for your own site analysis recordings and presentation, then head over to our shop ( Here ).

FAQ’s about site visit analysis

What is included in a site analysis.

As discussed above, site analysis typically includes the following elements:

• Site location and context: Understanding the location of the site in relation to the surrounding area, including climate, topography, neighboring buildings, and accessibility.
• Physical characteristics: Examining the site’s physical features, such as its size, shape, soil type, vegetation, and water sources.
• Utilities and infrastructure: Assessing the availability of utilities such as electricity, water, gas, and sewer, as well as the infrastructure, such as roads and transportation.
• Environmental considerations: Analyzing the site’s potential environmental impact and assessing any potential hazards, such as flooding or soil stability.
• Zoning and land-use regulations: Reviewing the local zoning and land-use regulations to determine the types of uses and development allowed on the site.
• Cultural and historical context: Examining the cultural and historical significance of the site and its surrounding area.
• Demographic information: Analyzing the demographic information of the surrounding area, including population, income, and age.
• Traffic and pedestrian flow: Studying the flow of vehicular and pedestrian traffic in the area to understand the impact on the site.

This information is used to inform the design of a building or development project, taking into account the unique characteristics and constraints of the site.

What are the steps of site analysis?

including the above, the steps involved in conducting a site analysis report typically include:

• Data Collection: Gather data and information about the site, including maps, aerial photos, zoning regulations, environmental reports, and other relevant documents.
• Site Observations: Conduct a site visit to observe and document the site’s physical and environmental conditions, such as topography, vegetation, water sources, and neighboring buildings.
• Context Analysis: Analyze the site’s location and context, including its surrounding area, access to transportation, and cultural and historical significance.
• Demographic Analysis: Study the demographic information of the surrounding area, including population, income, and age, to understand the potential market for the development project.
• Traffic and Pedestrian Flow Analysis: Study the flow of vehicular and pedestrian traffic in the area to understand the impact on the site.
• Synthesis: Synthesize the information gathered in the previous steps to develop a comprehensive understanding of the site and its potential.
• Recommendations: Based on the analysis, make recommendations for the development of the site, taking into account the unique characteristics and constraints of the site.

These steps help architects and planners to gain a deeper understanding of the site and to make informed decisions about the design and development of a building or project.

Every design project begins with site analysis … start it with confidence for free!.

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Donald Trump was convicted on felony charges. Will he go to prison?

A New York jury's historic conviction of Donald Trump on felony charges means his fate is now in the hands of the judge he has repeatedly ripped as "corrupt" and "incompetent."

Two experts told NBC News that it's unlikely Trump will be imprisoned based on his age, lack of a criminal record and other factors — and an analysis of thousands of cases found that very few people charged with the same crime receive jail time. But a third expert told NBC News he believes it is "substantially" likely Trump could end up behind bars.

Trump was convicted on 34 counts of falsifying business records , a class E felony that is punishable by a fine, probation or up to four years in prison per count. During the trial, Judge Juan Merchan threatened to put Trump behind bars for violating his gag order, but it’s unclear whether the former president will face similar consequences now. It's expected that any sentence would be imposed concurrently, instead of consecutively.

Former federal prosecutor Chuck Rosenberg, an NBC News analyst, said it's unlikely that Merchan would sentence Trump, 77, to any jail time, given his age and his status as a first-time, nonviolent offender. "I’d be very surprised if there's any sentence of incarceration at all," Rosenberg said. “Of course, he did spend a good bit of time insulting the judge who has the authority to incarcerate him.”

The next step for Trump at this point is his sentencing, which is set for July 11. Manhattan District Attorney Alvin Bragg would not comment Thursday on what type of sentence he’d seek, saying his office would do its speaking in court papers in the weeks ahead.

Arthur Aidala, a former prosecutor in the Brooklyn district attorney's office who's now a defense lawyer, said the judge will most likely use some of the time before sentencing to research similar cases to determine what the median sentence is.

"He wants to know before he sentences someone what the typical sentence is," Aidala said, and would consider other factors, like Trump's age and lack of a criminal record, while also taking into account the lack of injury caused by the crime. Aidala said he believes whatever punishment Merchan comes up with would be "a non-jail disposition."

An analysis conducted by Norm Eisen, who worked for House Democrats during Trump’s first impeachment, found that roughly 1 in 10 people who have been convicted of falsifying business records are imprisoned and that those cases typically involved other crimes.

Ron Kuby, a veteran New York criminal defense lawyer, took a different view.

“Judge Merchan is known for being a harsh sentencer when it comes to white-collar crimes committed by people who have wealth and privilege and power,” he said.

Kuby added he believes "it is substantially likely Judge Merchan will sentence Trump to jail or prison time," despite the logistical and practical complications that locking up a person with Secret Service protection would entail.

Kuby said that's because the criminal scheme went on for over a year and included a number of bad acts on Trump's part.

“It’s an entire course of conduct he was involved with — not just one bad decision,” he said.

Trump, however, most likely doesn't have to worry about missing the Republican National Convention, where he's expected to accept the party's nomination, even though it's taking place just days after his sentencing. Kuby said he'd most likely be able to remain free while he appeals the conviction.

Trump's behavior during the trial, including his flouting Merchan's gag order by making comments about witnesses and the jury, isn't likely to be a factor in the sentencing decision, Kuby said. It's also highly unlikely that comments that appeared to be aimed at sidestepping the gag order by Republican officials who attended the trial as Trump's guests will figure into Merchan's reasoning, Kuby added.

"If the judge is smart, he'd stay away from that," Kuby said. "The best way for judges not to get reversed in a sentencing is to stick to the facts and circumstances of the crimes and conviction."

Rosenberg said that despite Trump’s frequent criticisms of Merchan, which he likened to “a batter who’s been yelling at the umpire from before the first pitch,” Merchan appeared to run “a clean and fair trial.”

Rosenberg and Kuby agreed that Trump would appeal the verdict. Kuby said that could delay Trump's serving whatever punishment Merchan doles out for years, even if the appeal is ultimately unsuccessful.

His first appeal will be to the state Appellate Division, a midlevel appeals court, and it will almost certainly not decide the appeal until after the November election, Kuby said. If he loses there, he could then appeal to the state's highest court, the Court of Appeals. A loss there would be followed by a request to the U.S. Supreme Court to hear the case.

If all that fails, Kuby said, he could then try turning to federal court in another attempt to eventually get the case before the Supreme Court.

The appeals process typically takes a long time — Kuby said he had one client who staved off prison time for six years — but there's another potential complicating factor in this case.

"If he becomes president of the United States, he cannot be incarcerated in a state prison" while he's in office, Kuby said, because it could prevent him from fulfilling his constitutional duties. If he lost his appeals, "by the time he leaves office — if he leaves office — he'd be ready to be incarcerated," he said.

Dareh Gregorian is a politics reporter for NBC News.

Adam Reiss is a reporter and producer for NBC and MSNBC.