Medicare Providers, Suppliers Must Revalidate Enrollment by Early 2013

Transcription

1 CMS Prvider and Supplier Enrllment Revalidatin Tl Kit Medicare Prviders, Suppliers Must Revalidate Enrllment by Early 2013 Prepared by Kathryn Kuhn, RPh, Senir Clinical Assciate Leigh Davitian, JD, CEO Dumbartn Grup and Assciates, LLC A Health Care Plicy and Advcacy Firm Executive Summary All prviders and suppliers wh enrlled in the Medicare prgram prir t Friday, March 25, 2011, will be required t revalidate their enrllment under new risk screening criteria required by the Patient Prtectin and Affrdable Care Act, Sectin 6401(a). (Prviders/suppliers wh enrlled n r after Friday, March 25, 2011 have already been subject t this screening, and need nt revalidate at this time.) Similar requirements apply t Medicaid- r CHIP-enrlled prviders/suppliers. In the cntinued effrt t reduce fraud, waste, and abuse, CMS implemented new screening criteria t the Medicare prvider/supplier enrllment prcess beginning in March Newly-enrlling and revalidating prviders/suppliers are placed in ne f three screening categries limited, mderate, r high. Each screening categry represents the level f risk t the Medicare prgram fr a particular type f prvider/supplier and determines the degree f screening t be perfrmed by the Medicare Administrative Cntractr (MAC) prcessing the enrllment applicatin. Between nw and March 23, 2013, the MACs will be sending ntices t individual prviders/suppliers; please begin the revalidatin prcess as sn as yu hear frm yur MAC. Upn receipt f the revalidatin request, prviders/suppliers have 60 days frm the date f the ntice t update and submit cmplete enrllment frms (30 days fr DMEPOS suppliers). Failure t submit the enrllment frms as requested may result in the deactivatin f Medicare prvider/supplier billing privileges. The preferred methd and quickest way t revalidate enrllment infrmatin is t use the Internet-based PECOS (Prvider Enrllment, Chain, and Ownership System) at Payment f a $505 applicatin fee when enrlling r revalidating is required fr any prvider/supplier using the fllwing CMS paper-based 855 enrllment applicatins r assciated Internet-based PECOS enrllment applicatins: 855A, 855B (excluding physicians, physician grup practices, nn-physician practitiners, and nn-physician practitiner grups), and 855S. The fee must be paid via Please nte: CMS frms 855A, 855B, 855I, 855O, 855R and 855S all have been revised as f July 1, In rder t reduce the burden n the prvider, CMS is wrking t develp innvative technlgies and streamlined enrllment prcesses including Internet-based PECOS. Updates will cntinue t be shared with the prvider cmmunity as these effrts prgress. Fr mre cmplete infrmatin abut the new prvider/supplier revalidatin requirements and screening criteria, please cntinue t review the attached dcument r fr further guidance r assistance, please cntact a Dumbartn Grup Assciate at: inf@dumbartnassciates.cm. CMS Prvider and Supplier Enrllment Revalidatin Tl Kit Prepared by Dumbartn Grup and Assciates, LLC Page 1 f 11

2 Backgrund Pursuant t the Patient Prtectin and Affrdable Care Act, Sectin 6401(a), new federal regulatins released n February 2, 2011 expand CMS authrity t cmbat fraud, waste, and abuse t Medicare, Medicaid, and the Children s Health Insurance Prgram (CHIP). The intent f the legislatin is t prhibit unqualified individuals and entities frm btaining r maintaining enrllment in the Medicare and Medicaid Prgrams as prviders r suppliers; hwever, legitimate prviders and suppliers will need t understand the new requirements s that billing privileges are nt affected by a failure t cmply with the rules. The final regulatins became effective March 25, Enrllment Revalidatin As a result f the new federal regulatins, ALL Medicare-enrlled prviders r suppliers must re-enrll and resubmit revalidate the accuracy f their enrllment infrmatin every 5 years in rder t maintain their Medicare billing privileges (every 3 years fr DMEPOS suppliers). Similar requirements apply t Medicaid- r CHIP-enrlled prviders/suppliers. The new enrllment revalidatin requirements apply t: Newly-enrlling Medicare, Medicaid, and CHIP prviders and suppliers beginning n r after March 25, Currently-enrlled Medicare, Medicaid, and CHIP prviders and suppliers adding a new lcatin (nt changing lcatin) beginning n r after March 25, Currently-enrlled Medicare prgram prviders and suppliers if enrlled befre March 25, Currently-enrlled Medicaid-nly and/r CHIP-nly prviders and suppliers if enrlled befre March 25, Revalidatin Prcess 1. Currently-enrlled Medicare prviders/suppliers wh have nt re-enrlled with the Medicare prgram since March 2006 (March 2008 fr DMEPOS suppliers) shuld g nline and register with the Internet-based prvider/supplier enrllment recrd management system called the Prvider Enrllment, Chain, and Ownership System r PECOS. Nte: The PECOS system matches prvider/supplier infrmatin that is maintained in ther databases such as an entity s Legal Business Name (LBN) as reprted t the Internal Revenue Service r the Natinal Plan and Enumeratin System (NPPES) upn btaining a NPI. If such infrmatin is nt identically reprted, then prcessing delays will be incurred due t the develpment methd executed by the Medicare Administrative Cntractr (MAC) t gather the crrect infrmatin. 2. Prviders/suppliers will receive a letter frm the MAC instructing them when revalidatin is necessary. Between nw and March 23, 2013, the MAC will send ut ntices n a regular basis t begin the revalidatin prcess fr each prvider and supplier. Prviders and suppliers must wait t submit the revalidatin nly after being ntified by the MAC t d s. CMS Prvider and Supplier Enrllment Revalidatin Tl Kit Prepared by Dumbartn Grup and Assciates, LLC Page 2 f 11

3 3. Upn receipt f the revalidatin letter, prviders/suppliers are required t respnd t the request and cmplete the revalidatin applicatin within 60 calendar days f ntificatin (30 days fr DMEPOS suppliers). If the revalidatin applicatin is nt cmpleted within the required timeframe, then the prvider s/supplier s billing privileges are subject t revcatin r deactivatin. Cmpletin f the revalidatin applicatin requires verifying and updating the prvider/supplier enrllment data including any prvider/supplier-specific requirements established by Medicare (e.g., licensure, DMEPOS accreditatin, surety bnding, credentialing). Submissin f specific dcumentatin t verify prvider/supplier enrllment data may be required (e.g., IRS Frm CP 575 verifying a business entity s tax identificatin number, pharmacy DMEPOS accreditatin attestatin f exemptin statement). If using PECOS, enrllment frms are nt required t be mailed t the MAC, but ther supprting dcumentatin that is requested must be mailed t the MAC. 4. Sign the certificatin statement n the applicatin. Only the authrized fficial with the authrity t sign and certify the initial enrllment applicatin and attest t the veracity f the enrllment data may sign the certificatin statement n the applicatin. A delegated fficial des nt have this authrity. See Resurces sectin at the end f this dcument fr clarificatin n authrized versus delegated fficial. If using PECOS, enrllment frms are nt required t be mailed t the MAC, but the signed certificatin statement and ther supprting dcumentatin that is requested must be mailed t the MAC. 5. Pay the nn-refundable applicatin fee electrnically either via credit card, debit card, r electrnic check, and submit with the applicatin a cpy f their Pay.gv receipt as prf f payment. Fr the calendar year 2011, the applicatin fee is $505. (See als Applicatin Fee belw fr mre infrmatin.) On the Pay.gv website, enter CMS int the field under Search Public Frms. Click G and then click the link t CMS Medicare Applicatin Fee. 6. CMS reserves the right t perfrm unannunced n-site inspectins t verify a prvider/supplier is peratinal and t determine cmpliance with Medicare enrllment requirements. Site verificatin visits fr enrllment purpses are separate frm, and in additin t, site visits that may be perfrmed fr establishing cmpliance with cnditins f participatin. (See als Screening Requirements belw fr mre infrmatin.) 7. Irrespective f a prvider s/supplier s revalidatin schedule, any changes in enrllment data must be reprted including a change in phne number, business address, prvider/supplier credentials, etc., and prviders/suppliers must cntinue t meet the nging enrllment requirements fr its prvider r supplier type including any applicable state licensure r accreditatin requirements. On r after March 23, 2012, CMS may perfrm interim r ff-cycle revalidatins f its Medicare prviders r suppliers and may request a prvider r supplier t cnfirm and recertify the accuracy f their enrllment infrmatin maintained by CMS. These ff-cycle revalidatins are in additin t the regular CMS Prvider and Supplier Enrllment Revalidatin Tl Kit Prepared by Dumbartn Grup and Assciates, LLC Page 3 f 11

4 5-year revalidatins. Off-cycle revalidatins may be triggered as a result f randm cmpliance checks, infrmatin indicating lcal health care fraud prblems, natinal initiatives, cmplaints, r ther reasns that cause CMS t questin the cmpliance f the prvider r supplier with Medicare enrllment requirements. Interim revalidatins may include site visits. CMS will cntact prviders r suppliers t revalidate their enrllment fr an ff-cycle revalidatin. CMS als reserves the right t adjust the rutine 5-year revalidatin schedule t ccur n a mre frequent basis fr specific prvider r supplier types if it determines that cmplaints r ther evidence it receives indicate nncmpliance with the statute r regulatins. The revalidatin schedule may als be adjusted t ccur n a less frequent basis if CMS determines cmpliance with the regulatins fr a specific prvider r supplier type warrant less frequent validatin. If a change in the revalidatin schedule ccurs, CMS will ntify all affected prviders and suppliers at least 90 days in advance f implementing the change. Applicatin Fee Whether revalidating enrllment infrmatin, applying fr an additinal lcatin, r newly enrlling in the Medicare Prgram, prviders and suppliers must pay a nn-refundable applicatin fee. The fee is used t cver the cst f CMS s expanded prgram integrity effsrts. Individual physician practitiners r nnphysician practitiners (including nurse practitiners, CRNAs, ccupatinal therapists, speech/language pathlgists, and audilgists) and physician r nn-physician practitiner grups are exempted frm paying the applicatin fee. Fr the calendar year 2011, the applicatin fee is $505. Fee amunts fr future years will be adjusted by the percentage change in the cnsumer price index (fr all urban cnsumers) fr the 12-mnth perid ending n June 30 f the prir year. CMS will give Medicare enrllment administrative cntractrs and the public advance ntice f any change in the fee amunt fr the cming calendar year. The prvider/supplier must pay the applicatin fee electrnically thrugh Pay.gv, either via credit card, debit card, r electrnic check. On a regular basis, CMS will send the Medicare enrllment administrative cntractrs a listing f prviders and suppliers (the Fee Submitter List ) that have paid an applicatin fee via Pay.gv. Hwever, prviders/suppliers are strngly encuraged t submit with their applicatin a cpy f their Pay.gv receipt f payment. This may enable the cntractr t mre quickly verify that payment has been made. Medicaid Prgram State Medicaid agencies must revalidate the enrllment f ALL prviders/suppliers at least every 5 years. The agencies have the discretin t determine which prviders r prvider types t re-validate enrllment first. Hwever, in the first years f the cycle the agencies may chse t cnsider re-validating enrllment f prvider/supplier types that pse the greatest risk f fraud, waste r abuse t the Medicaid prgram and CHIP. The agencies shuld cmplete the first re-validatin cycle by 2015, with 20 percent f prviders being re-validated each year beginning States will als begin cllecting the applicatin fee frm prspective r re-enrlling prviders and suppliers in the Medicaid Prgram. Prviders/suppliers nt subject t the Medicaid applicatin fee include individual practitiners, prviders/suppliers wh have paid the applicatin fee in anther state s Medicaid prgram, and Medicare prviders/suppliers wh have already paid the Medicare applicatin fee. CMS Prvider and Supplier Enrllment Revalidatin Tl Kit Prepared by Dumbartn Grup and Assciates, LLC Page 4 f 11

5 Temprary Mratria n Enrllment f Prviders and Suppliers Additinally, the new regulatins permit CMS t impse a temprary mratrium n newly enrlling Medicare prviders and suppliers f a particular type in a specific gegraphic area if CMS determines that there is a significant ptential (high risk) fr fraud, waste r abuse with respect t the particular type f prvider r within a certain gegraphic regin, r bth. The mratrium extends t such prviders and suppliers underging expansin by establishing new lcatins, but nt t lcatin changes r changes in wnership (except changes in wnership fr hme health agencies requiring new enrllment). CMS is required t publicly annunce any such temprary mratrium in the Federal Register. A mratrium may be based n the identificatin f trends assciated with a significant ptential fr fraud, waste r abuse within a limited gegraphic area a highly disprprtinate number f prviders r suppliers in a categry relative t the number f beneficiaries, a rapid increase in a categry s enrllment applicatins, a state-impsed mratrium n Medicaid enrllment f a particular type f prvider r supplier, r n the recmmendatin f the HHS OIG, Department f Justice, r GAO identifying a prvider r supplier type as having a significant ptential fr abuse, waste r fraud t the Medicare Prgram. If any enrllment applicatin has been apprved by a Medicare cntractr, then a mratrium will nt apply even if the applicatin has nt been entered int PECOS. Initial mratriums may last six mnths, but CMS may extend a mratrium in six mnth increments at its discretin. States must als cmply with any mratrium issued by CMS by suspending enrllment f a categry f prviders/suppliers in its Medicaid prgram, unless the state determines that ding s will adversely affect Medicaid beneficiary access t care. Fr all prvider/supplier enrllments and revalidatins, the applicatins will be prcessed in accrdance with the screening prcedures described belw. Screening Requirements A MAC is required t screen all applicatins it receives fr initial enrllment, a new lcatin, and in respnse t a revalidatin request. CMS has defined three screening categries accrding t a particular type f prvider s r supplier s risk ptential fr fraud, waste and abuse limited, mderate, and high. Prvider and supplier types have been assigned t a categry based upn a risk assessment by CMS. The level f screening by the MAC n behalf f CMS increases with the categry risk ptential: Screening Categries and Screening Requirements Limited: Prviders/suppliers that pse the lwest level f risk will be placed in the "limited" screening categry and will be subject t the level f screening currently in effect fr this categry. Prvider/supplier types in the limited categry include: Physician r nn-physician practitiners (including nurse practitiners, CRNAs, ccupatinal therapists, speech/language pathlgists, and audilgists) and physician and nn-physician practitiner medical grups r clinics. Ambulatry surgical centers. Cmpetitive Acquisitin Prgram/Part B Vendrs. End-stage renal disease facilities. Federally qualified health centers. CMS Prvider and Supplier Enrllment Revalidatin Tl Kit Prepared by Dumbartn Grup and Assciates, LLC Page 5 f 11

6 Histcmpatibility labratries. Hspitals, including critical access hspitals, Department f Veterans Affairs hspitals, and ther federally wned hspital facilities. Health prgrams perated by an Indian Health Prgram (as defined in sectin 4(12) f the Indian Health Care Imprvement Act) r an urban Indian rganizatin (as defined in sectin 4(29) f the Indian Health Care Imprvement Act) that receives funding frm the Indian Health Service pursuant t Title V f the Indian Health Care Imprvement Act. Mammgraphy screening centers. Mass immunizatin rster billers Organ prcurement rganizatins. Pharmacies newly enrlling r revalidating via the CMS-855B applicatin. Radiatin therapy centers. Religius nn-medical health care institutins. Rural health clinics. Skilled nursing facilities. The required limited screening invlves: 1. Verificatin f any prvider/supplier-specific requirements established by Medicare n the prvider/supplier enrllment applicatin (e.g., DMEPOS accreditatin, surety bnding, pharmacy accreditatin attestatin exemptin statement). 2. License verificatins, which may include licensure checks acrss States (e.g., authenticatin f licensure and absence f any licensure limitatins). 3. Database checks, i.e., verificatin f: Scial Security Number (SSN); the Natinal Prvider Identifier (NPI); the Natinal Practitiner Data Bank (NPDB) licensure clearinghuse fr reprts n negative actins r sanctins against health care practitiners and entities; an HHS OIG exclusin frm Federal health care prgrams; taxpayer identificatin number; and the SSN Death Master File t determine if persnnel listed n the applicatin are deceased such as the applicant, wner, authrized fficial, delegated fficial, r a supervising physician. Mderate: Prviders that pse a mderate level f risk will be placed in the "mderate" screening categry and will be subject t all current screening measures impsed n prviders/suppliers in the limited screening categry, as well a mandatry unannunced site verificatin visit. Prvider/supplier types in the mderate categry include: Ambulance service suppliers. Cmmunity mental health centers. Cmprehensive utpatient rehabilitatin facilities. Hspice rganizatins. Independent clinical labratries. Independent diagnstic testing facilities. Physical therapists enrlling as individuals r as grup practices. Prtable x-ray suppliers. Revalidating hme health agencies. Revalidating DMEPOS suppliers revalidating via the CMS-855S applicatin including applicable retail, hme infusin, and lng-term care pharmacies. CMS Prvider and Supplier Enrllment Revalidatin Tl Kit Prepared by Dumbartn Grup and Assciates, LLC Page 6 f 11

7 The required mderate screening invlves: 1. All the screening requirements fr the limited screening categry. 2. Mandatry, unscheduled r unannunced site verificatin visits. Nte: Regardless f the prvider/supplier screening categry, CMS reserves the right t perfrm n-site inspectins t verify a prvider/supplier is peratinal and t determine cmpliance with Medicare enrllment requirements. Site verificatin visits fr enrllment purpses are separate frm, and in additin t, site visits that may be perfrmed fr establishing cmpliance with cnditins f participatin. Operatinal means the prvider/supplier: Has a qualified physical practice lcatin; Is pen t the public fr the purpse f prviding health care-related services (if applicable t that prvider r supplier type); Is prepared t submit valid Medicare claims; and Is prperly staffed, equipped, and stcked (as applicable, based n the type f facility r rganizatin, supplier specialty, r the services r items being rendered) t furnish these items r services. Reference: CMS Publicatin , Prgram Integrity Manual, Chapter 15, Sectin 1.1 High: Prviders that pse the highest level f risk fr fraud and abuse will be placed in the "high" screening categry and will be subject t all current screening measures impsed n prviders/suppliers in the mderate screening categry and a fingerprint-based criminal backgrund check. (The fingerprint-based criminal backgrund check is pstpned fr further public input and evaluatin.) The prvider/supplier types in the "high" risk categry include: Prspective (newly enrlling) hme health agencies. Prspective DMEPOS suppliers newly enrlling via the CMS-855S applicatin including applicable retail, hme infusin, and lng-term care pharmacies. Prviders/suppliers that have been reassigned frm either the "limited" r "mderate" categry as a result f a triggering event, which is defined as any ne f the fllwing: Impsitin f a payment suspensin within the previus 10 years. Terminatin r therwise precluded frm billing Medicaid. Exclusin by the HHS Office f Inspectr General (OIG). Revcatin f billing privileges within the previus 10 years. Exclusin frm any federal health care prgram. Any f the fllwing final adverse actins within the past 10 years: A Medicare-impsed revcatin f any Medicare billing privileges; Suspensin r revcatin f a license t prvide health care by any State licensing authrity; Revcatin r suspensin by an accreditatin rganizatin; A cnvictin f a Federal r State felny ffense preceding enrllment, revalidatin, r re-enrllment; r An exclusin r debarment frm participatin in a Federal r State health care prgram. At any time within 6 mnths frm the date a temprary mratrium is lifted fr a particular categry f prviders/suppliers. CMS Prvider and Supplier Enrllment Revalidatin Tl Kit Prepared by Dumbartn Grup and Assciates, LLC Page 7 f 11

8 The required high screening invlves: 1. All the screening requirements fr the mderate screening categry. 2. Fingerprint-based criminal histry recrd check f law enfrcement repsitries. (The fingerprintbased criminal backgrund check is pstpned fr further public input and evaluatin.) Nte: If a prvider culd fit within mre than ne risk categry described abve, the highest level f screening is applicable. CMS ntes that the risk categries are nt static and CMS may adjust the classificatin f prviders/suppliers by prpsed rulemaking; hwever, CMS reserves the right t redefine what cnstitutes a triggering event as nted abve withut frmal rulemaking. Medicaid Prgram Individual states will be respnsible fr implementing the new screening requirements fr thse prviders enrlling nly in Medicaid r CHIP. States will be allwed t rely n the screening results btained by the MACs fr prviders/suppliers wh are seeking dual enrllment in Medicare and Medicaid/CHIP. Fr Medicaid prviders/suppliers that d nt participate in the Medicare prgram, the state Medicaid agencies will have the discretin t evaluate the ptential risk f such prviders/suppliers and designate a risk categry fr them. In additin, every state Medicaid agency will nw be required t btain dates f birth and scial security numbers fr all managing emplyees f prviders/suppliers enrlling in Medicaid. Fr further guidance r assistance, please cntact a Dumbartn Grup Assciate at: inf@dumbartnassciates.cm. Resurces Federal Register Final Rule regarding prvider/supplier enrllment revalidatin and new applicatin/screening criteria titled: Medicare, Medicaid, and Children s Health Insurance Prgrams; Additinal Screening Requirements, Applicatin Fees, Temprary Enrllment Mratria, Payment Suspensins and Cmpliance Plans fr Prviders and Suppliers, published February 2, Cde f Federal Regulatins cdificatin f the abve regulatins n prvider/supplier enrllment revalidatin and new applicatin/screening criteria. G t then Title 42, Public Health, and then click n sectin 424, Cnditins fr Medicare Payment, and sectin 454, Medicaid Enrllment Requirements. Medicare Prgram Integrity Manual, Chapter 15, Medicare Enrllment See the additin f new sectin 19 titled, Applicatin Fees and Additinal Screening Requirements. Fr Online Infrmatin n CMS Medicare Enrllment fr Prviders and Suppliers CMS Prvider and Supplier Enrllment Revalidatin Tl Kit Prepared by Dumbartn Grup and Assciates, LLC Page 8 f 11

9 Medicare Enrllment Applicatins Internet-based Prvider Enrllment, Chain, and Ownership System (PECOS) PECOS is the preferred applicatin methd fr Medicare Prvider/Supplier Enrllment and Revalidatin. It is an Internet-based, nline applicatin versin f the paper-based CMS 855 applicatin frms. Hwever, the 855 frms are a gd reference and recmmended fr review t becme familiar with the cmprehensive enrllment applicatin requirements. The basics f PECOS shuld als be reviewed prir t accessing it the first time (refer t the belw FAQs and applicable educatinal fact sheets), in additin t reviewing the PECOS checklist that is available upn accessing PECOS nline. Fr nline access t PECOS g t: PECOS Frequently Asked Questins (FAQs) These FAQs area available frm Highmark Medicare Services, a Medicare Administrative Cntractr (MAC). T access the PECOS FAQs, g t: Frm 855B: Clinics/Grup Practices and Certain Other Suppliers (Fr Physician Practitiners/Physicians/Suppliers such as Pharmacies (except DMEPOS Suppliers)) Nte: If using r referring t the paper-based 855B enrllment frm, rely nly n the versin marked: Frm Apprved OMB NO (dated 07/11). MAC List by State: The enrllment administratr fr Suppliers, such as pharmacies, is a Medicare Administrative Cntractr (MAC). T access the list, g t: Frm 855S: Durable Medical Equipment, Prsthetics, Orthtics, and Supplies (DMEPOS) Suppliers Nte: If using r referring t the paper-based 855S enrllment frm, rely nly n the versin marked: Frm Apprved OMB N (dated 07/11). The DMEPOS enrllment administratr is the Natinal Supplier Clearinghuse (NSC). Palmett GBA is the entity under cntract with CMS t administer the NSC prgram. T cntact the NSC, g t: Educatinal Materials Implementatin f Prvider Enrllment Prvisins in CMS-6028-FC, MLN Matters Number: MM7350 This article is available frm the CMS Medicare Learning Netwrk (MLN).* It prvides a summary f the abve final rule published in the Federal Register n the new prvider/supplier enrllment revalidatin requirements and screening criteria. Further Details n the Revalidatin f Prvider Enrllment Infrmatin, MLN Matters Number: SE1126 This article is available frm the CMS MLN and supplements the abve MLN article. CMS Prvider and Supplier Enrllment Revalidatin Tl Kit Prepared by Dumbartn Grup and Assciates, LLC Page 9 f 11

10 The fllwing educatinal Fact Sheets are available frm the CMS MLN. The Fact Sheets are accessible via the CMS MLN prduct catalg at: The Basics f Medicare Enrllment fr Physicians and Other Part B Suppliers Suggested fr: Nn-physician practitiners, physicians, and ther suppliers (except DMEPOS Suppliers) that cmplete CMS Frm 855B. The Basics f Internet-based Prvider Enrllment, Chain and Ownership System (PECOS) fr Prvider and Supplier Organizatins Suggested fr: Prvider and supplier entities (except DMEPOS suppliers) that cmplete CMS Frm 855B. The Basics f Internet-based PECOS fr Durable Medical Equipment, Prsthetics, Orthtics, and Supplies (DMEPOS) Suppliers Suggested fr: DMEPOS suppliers; suppliers that cmplete CMS Frm 855S. Hw t Prtect Yur Identity Using the Prvider Enrllment, Chain and Ownership System (PECOS) Suggested fr: All Medicare prviders and suppliers. CMS Pharmacist Center Fr up-t-date infrmatin abut the Medicare Prgram fr pharmacists, g t the CMS Pharmacist Center at: Definitins: Medicare Enrllment Regarding Authrized versus Delegated Official An Authrized Official means an individual with wnership interest in and/r managing cntrl f the prvider/supplier and wh is legally respnsible fr prvider/supplier (fr example, chief executive fficer, chief financial fficer, general partner, chairman f the bard, r direct wner) and wh has been granted the legal authrity t enrll the prvider/supplier in the Medicare prgram, t make changes r updates t the prvider s/supplier s status in the Medicare prgram, and t cmmit the prvider/supplier t fully abide by the statutes, regulatins, and prgram instructins f the Medicare prgram. By his/her signature(s), an authrized fficial binds the prvider/supplier t all f the requirements listed in the Medicare Prvider/Supplier Enrllment Applicatin Certificatin Statement and acknwledges that the prvider/supplier may be denied entry t r revked frm the Medicare prgram if any requirements are nt met. All signatures must be riginal and in ink. Faxed, phtcpied, r stamped signatures will nt be accepted. Only an authrized fficial has the authrity t sign (1) the initial enrllment applicatin n behalf f the prvider/supplier r (2) the enrllment applicatin that must be submitted as part f the peridic revalidatin prcess. A delegated fficial des nt have this authrity. By signing the enrllment applicatin, an authrized fficial agrees t immediately ntify the MAC if any infrmatin furnished n the applicatin is nt true, crrect, r cmplete. In additin, an authrized fficial, by his/her signature, agrees t ntify the MAC f any future changes t the infrmatin cntained in the enrllment frm, after the prvider/supplier is enrlled in Medicare, in accrdance with the CMS Prvider and Supplier Enrllment Revalidatin Tl Kit Prepared by Dumbartn Grup and Assciates, LLC Page 10 f 11

11 timeframes established in 42 C.F.R (b). (IDTF changes f infrmatin must be reprted in accrdance with 42 C.F.R ) A Delegated Official means an individual wh is delegated by an authrized fficial the authrity t reprt changes and updates t the prvider s/supplier s enrllment recrd. A delegated fficial must be an individual with an wnership r cntrl interest in (i.e., the term persn with an wnership r cntrl interest means, with respect t an entity, a persn wh directly r indirectly has an wnership interest f 5% r mre in the prvider/supplier; r fficers and directrs f the prvider/supplier if the prvider/supplier is a crpratin (whether fr-prfit r nn-prfit); r all individuals with a partnership interest in the prvider/supplier regardless f a partner s percentage f wnership; r a managing emplyee a general manager, business manager, administratr, directr, r ther individual wh exercises peratinal r managerial cntrl ver, r wh directly r indirectly cnducts, the day-t-day peratins f the prvider/supplier, either under cntract r thrugh sme ther arrangement, regardless f whether the individual is a W-2 emplyee f the prvider/supplier). Delegated fficials may nt delegate their authrity t any ther individual. Only an authrized fficial may delegate the authrity t make changes and/r updates t the prvider s/supplier s Medicare status. Even when delegated fficials are reprted in the enrllment applicatin, an authrized fficial retains the authrity t make any such changes and/r updates by prviding his r her printed name, signature, and date f signature. Authrized fficials and delegated fficials must be reprted in the revalidatin applicatin r n a previus applicatin t the same MAC if a change in authrized and/r delegated fficials ccurs. The first time an authrized and/r delegated fficial is reprted, Sectin 6 f the prvider/supplier enrllment applicatin fr that individual must be cmpleted and submitted. Fr further guidance r assistance, please cntact a Dumbartn Grup Assciate at: inf@dumbartnassciates.cm. #### Disclaimer: All f the material in this dcument is intended fr general infrmatin purpses nly and des nt and is nt intended t represent legal advice. Cnsult with legal cunsel t determine hw laws r decisins discussed herein apply t yur specific circumstances. CMS Prvider and Supplier Enrllment Revalidatin Tl Kit Prepared by Dumbartn Grup and Assciates, LLC Page 11 f 11