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Rebuttal Process

What is a Rebuttal

An opportunity for a provider or supplier who has been deactivated to demonstrate that it meets all applicable enrollment requirements and should not have had their Medicare billing privileges deactivated.

When is Rebuttal applicable

When deactivated for one of the following deactivation reasons:

  1. Not submitting any Medicare claims for 12 consecutive calendar months.
  2. Not reporting a change to the information supplied on the enrollment application within applicable timeframe. Changes that must be reported within 90 calendar days include but are not limited to, a change in practice location, a change of any managing employee, or a change in billing services.  Changes that must be reported within 30 calendar days include a change in ownership or control.
  3. Not furnishing complete and accurate information and all supporting documentation within 90 calendar days of receipt of notification from CMS to submit an enrollment application, or resubmit and certify to the accuracy of its enrollment information.

Note that all deactivation letters sent on or after 12/31/19 will include rebuttal rights if applicable.

When must Rebuttal be submitted

Within 20 calendar days from the date of the deactivation notice.

What must be included with Rebuttal

  1. The facts or issues with which the provider or supplier disagrees, and the reasons for disagreement;
  2. All documentation and information the provider or supplier would like to be considered in reviewing the deactivation;
  3. Must be in the form of a letter that is signed and dated by the individual provider, supplier, the authorized or delegated official, or a legal representative, as defined in 42 CFR § 498.10.
    • If the legal representative is an attorney, the attorney must include a statement that he or she has the authority to represent the provider or supplier.
    • If the legal representative is not an attorney, the provider or supplier must file written notice of the appointment of a representative with the MAC. This notice of appointment must be signed and dated by the individual provider or supplier, the authorized or delegated official, or a legal representative
  4. Rebuttal form available here.PDF

Where is Rebuttal request sent to

Rebuttal requests must be submitted by mail to the following address:

CGS Administrators, LLC
J15 Part A Provider Enrollment Department
P.O. Box 20004
Nashville, TN 37202-0013

MAC processing of Rebuttals

All accepted rebuttal submissions shall be processed within 30 calendar days of the date of receipt, or, if development is required, within 30 days from the date the developed information was received.


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