In response to the concerns we raised last year, the MPS has been notified that Medicaid now allows Ordering, Referring, and Prescribing (ORP) provider enrollment for those who contract privately with patients. This is instead of enrolling as a rendering provider (and accepting Medicaid contract terms), which they had insisted on previously. The ORP option accommodates psychiatrists having private pay arrangements with patients while Medicaid pays for the labs and prescriptions they order. This new option is somewhat similar to opting out of Medicare but, according to Medicaid Provider Services, there is no 2-year minimum requirement, i.e. someone can sign up for ORP one week and then change to a provider the next week. Also, there is no Medicaid requirement for a signed written agreement with the patient, although that would be best practice.
As a reminder, last year Medicaid began rejecting payment for prescriptions if the prescriber was not enrolled as a provider in the Medicaid program. This practice was put on hold after the MPS raised alarm that some psychiatric patients were no longer able to obtain their medicines. As a precaution, some non-enrolled psychiatrists referred their patients to other psychiatrists who participate in Medicaid. Others continued seeing their Medicaid patients during the hiatus. Those who waited now have their answer: enrolling as an ORP provider by October 1 will enable the treatment relationship to be preserved as well as the labs and prescriptions to be covered.
It’s important to note that you must enroll as an ORP or as a rendering provider for prescriptions to be paid after October 1. One or the other is required or payment for prescriptions and labs will be rejected again.
There is some screening with the ORP enrollment via ePREP (e.g. licensure, etc), which is the same as required for enrolling as a provider, but there is no provider agreement and no contractual relationship with Medicaid. The ePREP process may be confusing so there are webinars scheduled and there are other online resources. Please use the ORP application on ePREP. The enrollment instructions help get into the portal on the correct path, but continue as appropriate to your situation as the rest of the steps depend somewhat how you complete the form. Please contact firstname.lastname@example.org with questions about ORP policies or enrollment.
After initial enrollment, the provider will need to upload when the medical license renews and revalidate every 5 years.
Please note: Each year many Marylanders enroll in Medicaid as one of the options on the health insurance exchange established under the Affordable Care Act. Be sure to ask all private pay patients whether they use Medicaid to cover their medicines and labs. If so, you must be enrolled as ORP to enable reimbursement.