In a sweeping effort to remain up to date with all applicable federal and NYS laws, regulations and policies concerning your pharmaceutical practice, we write this correspondence with the intention of providing information regarding the updated Medicare and Medicaid enrollment policies that were just implemented.

First, OMIG has issued new policies surrounding requirements for Medicare billing pharmacies, namely those who wish to be involved in Medicaid. Specifically, if a pharmacy is enrolled in, or applying for, the 0441 category of service in Medicaid, they must be fully participating in Medicare as a condition of continued enrollment or, alternatively, as a prerequisite to new enrollment. This implies that Medicare forms CMS-855B, CMS 855S and CMS-460 all are required.

Further, it follows that the conditions that surround being a Medicaid enrolled pharmacy (COS 0441, 0161, 0288) are outlined and updated as follows:

• Have a Medicaid enrolled Supervising Pharmacist;
• Are fully operational, open, and dispensing medications;
• Are fully enrolled in Medicare as a participating provider with the submission of form CMS-460 and both CMS-885B (allows drug claim billing to Medicare Part B) and CMS-855S (allows diabetic supplies and enteral nutrition billing to Medicare Part B);
• Maintain inventory of commonly dispensed medications and supplies (e.g., diabetic), that are applicable to the patients they serve;
• Maintain adequate hours of operation, as needed for Medicaid members that they serve;
• Are able to respond to urgent or emergent issues that occur after normal operating hours;
• Follow all federal and NYS laws, regulations and policies;
• Maintain applicable State registration(s) including Medicaid enrollment and registration in state of service location and NY non-resident registration; and
• Applicant pharmacy submitted all required forms and information.

If you feel as if, or are uncertain if, your practice is in compliance with the new updates, please do not hesitate to reach out to us with any questions you may have. Additionally, if you are interested in enrolling for Medicaid, we are at the forefront of this new policy, and we would be delighted to assist your pharmacy through the stringent process that is Medicare/Medicaid enrollment.