Get Your 855s Ready – New Forms Are Up Just In Time for the CMS Revalidation Project
If you haven’t gotten your letter from CMS yet, chances are good that you will soon. CMS recently began sending letters to providers seeking revalidations of CMS-855A forms in a large-scale revalidation effort. It’s underway now and will continue through March 23, 2013.
For revalidation, you must fill in the entire 855 form, and it’s probably different than the most recent one you completed. The current version was effective July 2011 and has more changes than any other in recent memory. You’ll have to review and complete this one carefully. And you’ll have 60 days from the postmark on CMS’ letter to get it done.
Sections 5 and 6 (relating to ownership) always seem to be toughest to complete. And, of course, the new form made them even more challenging. There is some relief for the bleary-eyed souls who work with these forms. One of the additions to these sections is a requirement that percentage information be provided. Fortunately, CMS acknowledged how difficult (impossible!) this determination can be and offered us some relief. In its “Update for Providers On Completing the Medicare Enrollment Application” released on October 27, 2011, CMS instructed:
The July 2011 version of the CMS-855A application contains various new data elements in sections 5 and 6. This message notifies providers that they need not complete the following data elements on either the paper or Internet-Based PECOS versions of the CMS-855A application:
Section 5 OWNERSHIP INTEREST AND/OR MANAGING CONTROL INFORMATION (ORGANIZATONS)
- “Exact percentage of operational/managerial control this organization has in the provider”
Section 6 OWNERSHIP INTEREST AND/OR MANAGING CONTROL INFORMATION (INDIVIDUALS)
- “Exact percentage of control as an Officer this individual has in the provider”
- “Exact percentage of control as a Director this individual has in the provider”
- “Exact percentage of management control this individual has in the provider” (under the “W-2 Managing Employee” heading)
- “Exact percentage of this contracted managing employee’s control in the provider”
- “Exact percentage of operational/managerial control this individual has in the provider”
In addition, under the "Other ownership or control/interest" headings in sections 5 and 6, the “Exact percentage of ownership or control/interest…” data element need not be completed if the organization/individual does not have an ownership, partnership, mortgage, security, or other quantifiable interest in the provider.
The Medicare contractors (who process these forms) are in the loop too, as they also received this guidance. Good luck to us all as we push this latest pile of paper around on our desks.
Emily Black Grey is a partner in Breazeale, Sachse, & Wilson L.L.P.’s Baton Rouge office and is the manager of its Health Care Section.