Effective July 2011, the Centers for Medicare & Medicaid Services (CMS) adopted a revised Medicare Enrollment Application – Institutional Providers CMS-855A (CMS-855A). Some of the more significant changes are set forth below in italicized text:
- Formerly, page 1 of the CMS-855A stated, “WHO SHOULD SUBMIT THIS APPLICATION”; the revised CMS-855A states, “WHO SHOULD COMPLETE THIS APPLICATION.”Additional instructions also are provided in the revised CMS-855A.
Institutional Providers can apply for enrollment in the Medicare program or make a change in their enrollment information using either:
- The Internet-based Provider Enrollment Chain and Ownership System (PECOS), or
- The paper enrollment application process (e.g., CMS-855A).
- On page 2 of the CMS-855A, under OBTAINING MEDICARE APPROVAL, another step is added in the Medicare approval process.
- A CMS contractor conducts a second contractor review, as needed, to verify that a provider continues to meet the enrollment requirements prior to granting Medicare billing privileges.
- In SECTION 2: IDENTIFYING INFORMATION – SPECIAL ENROLLMENT NOTES, an additional note has been added defining physician-owned hospital. This is important because a physician-owned hospital has additional reporting requirements.
- There is a title change in Section 3. SECTION 3: FINAL ADVERSE LEGAL ACTIONS/CONVICTIONS. Formerly, the word FINAL was not included in the title.
- In SECTION 4: PRACTICE LOCATION INFORMATION, in the subsection, Hospitals and HHAs only (Identify type of practice location), an additional type of practice location is listed, Main/Primary Hospital Location.
The title has also been changed regarding a second medical record storage facility. The title now reads, “Second Medical Record Storage Facility for Current and Former Patients.” Formerly, it was titled Second Medical Record Storage Facility.
- SECTION 5: OWNERSHIP INTEREST AND/OR MANAGING CONTROL INFORMATION (ORGANIZATIONS) has been revised significantly; therefore, special attention should be given to this section when completing the CMS-855A.
- SECTION 17: SUPPORTING DOCUMENTS now contains an additional statement regarding the fee-for-service contractor. “The fee-for-service…The Medicare fee-for-service contractor may also request documents from you, other than those identified in this section 17, as are necessary to bill Medicare.”
Under subsection, MANDATORY, IF APPLICABLE, there are two (2) additional requests listed:
- Copy of IRS Determination Letter, if provider is registered with the IRS as non-profit;
- Written confirmation from the IRS confirming your Limited Liability Company (LLC) is automatically classified as a Disregarded Entity. (e.g., Form 8832). NOTE: A disregarded entity is an eligible entity that is treated as an entity not separate from its single owner for income tax purposes
- Following Section 17 is ATTACHMENT 1: PHYSICIAN-OWNED HOSPITALS ONLY. Attachment 1 consists of six (6) pages that must be completed if a provider is deemed a physician-owned hospital as defined in Section 2.
The CMS-855A has been significantly reformatted which should make it more user-friendly, but has also increased the number of pages of the form. No notice has been provided regarding how long the Medicare Administrative Contractors will continue to accept the previous version; therefore, providers should consider using the new CMS-855A to avoid delays in enrollment and/or reimbursement.
If you have any questions regarding the new CMS-855A, please contact:
- Todd Selby at tselby@hallrender.com or 317.977.1440
; - Brian Jent at bjent@hallrender.com or 317.977.1402; or
- Your regular Hall Render attorney.
This publication is intended for general information purposes only and does not and is not intended to constitute legal advice. The reader must consult with legal counsel to determine how laws or decisions discussed herein apply to the reader’s specific circumstances.
