In an April 6, 2012 Survey & Certification Letter (S&C: 12-26-HHA) [PDF] CMS reminded Home Health Agencies (HHAs) of the January 1, 2010 change in the process for an HHA to reactivate its billing privileges. Since the June 2006 overhaul of the Medicare enrollment rules, CMS and its contractors have had the authority under 42 C.F.R. § 424.540(a) to deactivate Medicare billing privileges when:

- A provider or supplier fails to submit any Medicare claims during a 12-month time period, or

- A provider or supplier does not report changes in its enrollment data within the time period required to report such changes.

Deactivation is the temporary suspension of billing privileges. It is not a final action and has no effect on the provider's or supplier's participation agreement. When the regulations were changed to authorize deactivations, CMS outlined the procedures that must be followed to have billing privileges restored, noting that reactivations would not require a new survey.