Email Alert
July 21, 2011
By Jeanne Vance*
The Centers for Medicare & Medicaid Services (CMS) has published revised Medicare enrollment forms for all provider and supplier types. The new forms list an effective date of July 1, 2011, but were not available on the CMS website until July 5, 2011.
CMS processes Medicare enrollment for providers and suppliers using the following enrollment forms: CMS 855A—for institutional providers; CMS 855B—for clinics/group practices and certain other Medicare Part B suppliers; CMS 855S—for durable medical equipment, prosthetics, orthotics, and supplies suppliers; CMS 855I—for physicians and certain nonphysician practitioners; CMS 855R—for physicians and certain non-physician practitioners seeking to reassign Medicare payments to a Medicare provider/supplier; and CMS 8550—for physician and non-physician enrollment that is solely for the purpose of ordering/referring patients for Medicare benefits. The CMS 460 form (participating provider agreement) and CMS 588 form (electronic transfer funds authorization agreement), which are also used for Medicare enrollment purposes, were not revised.
Revisions to the forms include the following:
855A
New Instructions and Content Required Regarding Disclosure of Ownership/Managing Control Interests
The updated CMS 855A form has extensive new instructions regarding reporting ownership and managing control interests, including new instructions regarding when to report mortgages and security interests in the provider or its assets, and a clarification that some limited partnership interests in the provider entity need not be reported. The modifications to the instructions regarding reporting of ownership and investment interests in the form CMS 855A did not carry over to the other new CMS 855 enrollment forms, and in at least one instance relating to limited partner reporting, provide different instructions.
Additional New Required Content
The revised form CMS 855A now requires the following information: identification of the existence of a hospital's compliance plan; identification of whether the hospital is physician-owned as well as an additional enrollment application attachment specific to physician-owned hospitals; and identification of the supplier as proprietary or nonprofit.
855B, 855S, and 855I
New Required Content
The revised forms CMS 855B, 855S, and 855I now require the following information: identification of the supplier as proprietary or nonprofit; reporting of accreditation for independent diagnostic testing facility suppliers that will bill the Medicare program for advanced diagnostic imaging services; and the place and country of birth for individuals that have an ownership or managing control interest in the supplier.
Additional Modification
CMS has removed the enrollment distinction in the form CMS 855B between single specialty and multi-specialty medical groups.
855O
This paper form was not available on the CMS website prior to the recent release of new forms. It is similar to form CMS 855I.
CMS has not yet specified what effect, if any, the release of the new forms, including the required new content, will have on pending enrollment applications that were submitted prior to the release of the new forms. Also, the new enrollment forms do not reference the new Medicare enrollment fees that went into effect in March 2011. According to informal (not necessarily binding) guidance from a source at Medicare Administrative Contractor Palmetto GBA, many providers that are subject to the new enrollment fees are not making payment until they are notified by Palmetto GBA to do so after the enrollment application has been submitted.
*We would like to thank Jeanne Vance, Esquire (Salem & Green, Sacramento, CA), for providing this email alert. We would also like to thank the Regulation, Accreditation, and Payment Practice Group for sharing this email alert with the In-House Counsel Practice Group members.