If your facility treats Medicare patients, you know—or have surely heard—about the 855 form. Actually, the Centers for Medicare & Medicaid Services (CMS) puts out seven versions of Form 855, and the smallest one is five pages long and can take hours to complete, say those in the field. Filling out all of them is a job all to itself.
For a small provider with a hospital as the main hub, filling out and filing the CMS-855-A form make take upwards of a week, warns compliance consultant Duane C. Abbey, who tackles the forms in an upcoming conference for ProfEdOnDemand, “Medicare Enrollment Update for 2018.” Abbey aims his conference at claim filers, coders and billers, compliance personnel, financial personnel, accreditation and licensing personnel, physicians and non-physician practitioners, cost report personnel, and others interested in Medicare billing privileges.
CMS has a fairly straightforward mission in requiring the 855 forms. It wants to know everything about you!—who you are, what you are, where you are located, who owns you, who controls you, if you’ve had past troubles, if there are any associated organizations, and if it is appropriate for you to file claims and be paid by Medicare.
The trick is to provide that information exactly as CMS requires. And while there has been no formal change in guidance, over time, the interpretations of and guidance for the enrollment process evolve—leaving you to play catch up, Abbey notes.
Before You Sharpen Your Pencil, Answer Some Basic Questions
There are a handful of fundamental questions to answer when readying to complete the forms:
- Who fills them out?
- Can they be filed electronically?
- Do the forms need to be updated, and if so when and how?
- Which forms pertain to you?
The 855 forms—as well as other required reporting, such as National Provider Identifiers (NPIs)—are critical to Medicare enrollment, Abbey says, especially with regard to the revalidation process. In other words, physicians and clinics must become expert at providing compliant information CMS has begun a study to assess the data match between the NPI and a facility’s legal business name. Facilities need to know if their NPI data is correct and up to date.
Learn What CMS Is Looking For
Filers need to be ready to detail their Provider, Enrollment, Chain and Ownership System (PECOS), NPIs, and business organizational structures. For the organizational structure, filers will need to be ready to explain or provide:
- Legal business name (vs. a doing-business-as)
- How the company is structured, as in who owns and operates different parts of it
- If there are any provider-based organizations such as clinics
- TINs, Financial Identification Numbers and Employer Identification Numbers
Another quandary: Who will take charge of this mountain of paperwork? The forms will need to be researched, filled out and filed. This could be one person’s job or a task for an entire team.
The 855 Forms: A Primer
According to Abbey, the following forms are all part of the Form 855 suite:
- Form 855-A is for providers that bill Medicare fiscal intermediaries, such as hospitals and skilled nursing facilities. File it for initial enrollment, revalidation, change of information, voluntary termination of a provider billing number, or change of ownership. Its 17 sections span 54 pagers plus any special attachments.
- Form 855-B is for healthcare suppliers that bill Medicare carriers—typically, this is a medical clinic. The form is filed to the regional carrier and is submitted for initial enrollment, reactivation, revalidation, change of information, TIN change, or voluntary termination of billing number. It has 17 sections spanning 49 pages plus special attachments.
- Form 855-I is for individual health care practitioners and is filed to the geographic carrier. File it for initial enrollment, revalidation, change of information, or voluntary deactivation of a billing number. It has 17 sections totaling 28 pages.
- Form 855-R is for individual healthcare practitioners reassigning Medicare benefits and is filed to the geographic carrier. File it when you add a new reassignment, terminate a current reassignment, change income reporting status, or attest to current reassignment. It the shortest of the bunch at just five pages.
- Form 855-O is for ordering or referring physicians and non-physician practitioners. File it for initial enrollment, revalidation, change of information, or voluntary deactivation of a billing number. At eight sections spanning nine pages, this is one of the newer forms—it showed up in 2013 and is for physicians and practitioners who would not normally apply to be in the Medicare program but who can order or refer patients for services.
- Form 855-S covers a wide variety of durable medical equipment suppliers, ranging from department stores to skilled nursing facilities and oxygen suppliers. File it to the national supplier clearinghouse for first time enrollment, revalidation, a new business location with the same or different TIN, reactivation, or voluntary termination. It has 15 sections totaling 26 pages and is regarded as one of the tougher forms to file.
- Form 855-POH is the annual report of physician-owned hospital ownership or investment interest. It has just five sections filling seven pages.
For a facility new to the Form 855, the above information should give you a good start. But if you want to learn more about how to fill out the forms, check out ProfEdOnDemand’s conferences on hospital compliance, which cover everything from safety measures and resource management to business structures and legal implications of the latest CMS regulations.
