On June 16, 2021, the Provider Reimbursement Review Board (the “PRRB” or the “Board”) issued Alert 21, announcing major revisions to the PRRB Rules and the adoption of mandatory electronic filing, effective November 1, 2021. In doing so, the PRRB issued a revised edition of the PRRB Rules (version 3.0), also effective November 1, 2021. The most significant of these revisions are summarized below. The PRRB has requested comments on the revised PRRB Rules by July 30, 2021, following the review of which the PRRB will publish any further revisions to the Rules by October 1, 2021. Alert 21 also updated the PRRB’s mailing address, effectively immediately, to its new permanent home: Provider Reimbursement Review Board Summary of the Most Significant Provisions of the New Rules The Board’s Order adopting mandatory electronic filing, and the accompanying revised PRRB Rules implementing this mandate, provide the most significant changes to the PRRB’s procedures since August 2018. Of greatest importance, the PRRB’s “Order No. 1: Mandatory Electronic Filing” means that, effective November 1, 2021, all submissions to the Board for new or pending appeals must be filed electronically using the PRRB’s electronic filing system [the Office of Hearings Case and Document Management System (“OH CDMS”)], unless the PRRB grants an exemption. Other significant revisions in the 102-page revised Rules include: Significant procedural changes Changes in filing requirements Changes in hearing procedures Changes in provider representative responsibilities and supplemental Board directives *** The PRRB invites comments, suggestions, and other feedback on the revised Rules from all interested individuals, providers, government contractors, and other organizations, via e-mail only to PRRB@cms.hhs.gov by Friday, July 30, 2021. To the extent the Board further revises the PRRB Rules, it will publish such revisions by Friday, October 1, 2021. Hooper, Lundy & Bookman is available to assist with submission of comments and feedback to the revised Rules, and we also welcome your input for inclusion in the comments that we intend to submit. For further information, please contact Kelly Carroll, Bob Roth or David Vernon in Washington D.C., Sven Collins in Denver, Nina Adatia Marsden in Los Angeles, or your regular Hooper, Lundy & Bookman contact. PRRB Announces New Address, Mandatory Electronic Filing, and Significant Proposed Changes to Rules, Inviting Comments on or before July 30, 2021
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