The North Carolina Medical Society is ready to update its previous recommendation that physician assistants (PAs) hold their Medicaid enrollment applications.  NCMS now believes that many of the risks of enrollment originally identified in 2011 have been addressed, and that PAs and medical practices should feel comfortable proceeding with the enrollment process.

Medicaid has not established a new deadline specifically requiring PAs to direct enroll.  However, NCMS now believes that the following factors and coming changes weigh in favor of enrollment:

•  No Unilateral Rate Changes.  The act of enrolling in Medicaid will not have an effect on PA payment rates.  Any payment rate modifications in Medicaid must first be authorized by the state legislature.  Until the General Assembly says otherwise, enrolled PAs will continue to be paid at 100% of the physician rate.
•  Rulemaking and Legal Authority.  At the urging of the NCMS and NC Academy of Physician Assistants, Medicaid has begun the agency rulemaking process to clarify provider enrollment requirements, including an explicit statement that PAs who treat Medicaid patients must be direct enrolled.  You may recall that NCMS’s position was that Medicaid could not unilaterally require PA enrollment without first initiating and completing the rulemaking process.
•  Prescriber Enrollment.  Medicaid is under pressure to implement a related federal requirement that all Medicaid prescribers be enrolled by April 1, 2013. You can read Medicaid’s February 2013 Bulletin article on the topic here.  NOTE: NCMS continues to urge Medicaid (1) to delay the implementation date of the prescriber requirement beyond April 1, and (2) to secure a workable exemption to this requirement for resident physicians.  Medicaid officials have been receptive to these requests but have not yet announced a decision.
•  Enhanced PCP Payments.  Coming soon, Medicaid will implement the Affordable Care Act’s PCP Payment Parity rule.  Under this program, eligible primary care providers, including PAs, can receive Medicare rates when providing certain primary care services to Medicaid patients.  While this detail has not yet been determined by NC Medicaid, it is foreseeable that PAs will need to register/attest for the enhanced rates by using their own Medicaid provider numbers, which will first require direct enrollment.  You can read more about the status of PCP payment parity here. 
•  Processing Times.  Medicaid and its enrollment vendor, CSC, are now better prepared to accept and process PA enrollment applications through the online NCTracks system than a year ago.  The current processing time for a complete, clean application is approximately 20 business days.
•  MMIS Transition.  Enrolling now, as opposed to later in the year, may avoid glitches or other unforeseen delays related to Medicaid’s transition to its new Medicaid Management Information System (MMIS), which is currently scheduled for July 1.

NCMS has taken a leading role in ensuring that the Medicaid program implements the PA enrollment requirement in a clear, transparent manner, and we will continue to watch this closely.

Review our efforts and previous bulletin announcements on this topic below:

NCMS and NCAPA Petition Medicaid’s PA Enrollment Requirements

They Just Aren’t Getting It: Medicaid Again Announces Enrollment Deadline for PAs & NPs