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04/07/2008
CMS Releases Revised 855 Medicare Enrollment Applications

On March 26, 2008, the Centers for Medicare and Medicaid Services (“CMS”) released revised versions of the CMS-855A, B, I and S Medicare provider/supplier enrollment applications on its website.  With the exception of providers enrolling as a specialty hospital on the 855A form, Medicare contractors will continue to accept the previous 2006 version of the application through June 2008.  However, CMS is encouraging providers and suppliers to begin using the new enrollment applications immediately.  

Many of the changes reflect CMS’ implementation of the National Provider Identifier (“NPI”) system and subsequent issues with proper cross-referencing of NPI and legacy Medicare provider/supplier numbers.  Additionally, for providers and suppliers other than DME suppliers, CMS has done away with the requirement that an NPI confirmation e-mail or letter accompany every enrollment and change of information.  The significant changes to the applications are as follows: 

Changes to CMS-855A (Institutional Providers)
  • Section 2.A.2.: Adds “Specialty Hospital” provider type designation.
  • Section 4 instructions: Clarifies definition of “primary practice location” to include requirement that the primary practice location address must be the one associated with the NPI used to bill for Medicare services.
  • Section 4.A.: Expands the number of NPI-Medicare provider number combinations that a provider may enter from one to five. Requires that an NPI-provider number combination must be listed for each practice location. Requires that all NPI-Medicare provider number combinations associated with each practice location be listed.
  • Section 2.B.1: Removes “Year-End Cost Report Date” box.
  • Section 17: Removes requirement that providers attach an NPI confirmation e-mail or letter to their application.

Changes to CMS-855B (Clinics/Group Practices and Certain Other Suppliers)
  • Throughout: Provides additional specifics regarding reporting of changes to supplier information.
  • Section 2.A.: Removes “Voluntary Health/Charitable Agency” supplier type designation.
  • Section 4.A.: Expands the number of NPI-Medicare supplier number combinations that a supplier may enter from one to five. Requires that an NPI-supplier number combination must be listed for each practice location. Requires that all NPI-Medicare supplier number combinations associated with each practice location be listed.
  • Section 17: Removes requirement that suppliers attach an NPI confirmation e-mail or letter to their application.
  • Section 17: Requires Independent Diagnostic Testing Facilities (“IDTFs”) submit copies of comprehensive liability insurance policies.
  • Attachment 2: Adds listing of the IDTF standards.
  • Attachment 2: Adds explanation of the IDTF liability insurance requirements.

Changes to CMS-855I (Physicians and Non-Physician Practitioners)
  • Section 17: Removes requirement that providers attach an NPI confirmation e-mail or letter to their application.

Changes to CMS-855S (DMEPOS Suppliers)
  • Page 31: Revises supplier standards list to reflect additional standards enacted since 2006 application version.

The revised CMS 855 applications may be accessed on the CMS website at http://www.cms.hhs.gov/CMSForms/.

For more information on this new requirement, please feel free to contact Jack Thompson at 615.252.4633 or , or another member of the Boult Cummings Health Care Team.

Authors:
Jack C. Thompson

Related Practice Areas:
Health Care , Health Care Operations and Compliance



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