PECOS Compliance Review: Refresh Your Knowledge of All 7 CMS-855 Forms

Filling out long, complicated forms is likely not a favorite task. Nevertheless, doing so is a critical part of your job if your facility treats Medicare patients. One (or, seven) of the forms you’ll see most is the set of paperwork known as CMS-855—and completing it can be confusing, warns healthcare compliance consultant Duane Abbey.

To stay compliant with the Provider Enrolment and Chain/Ownership System (PECOS) and its accompanying forms, periodic training on the labyrinth of guidelines is imperative, he affirms. In his AudioSolutionz webinar, “Medicare Enrollment Update for 2019,” Abbey goes over the various CMS-855 forms, including how to fill them out—and how and when to resubmit them as part of Medicare’s revalidation process.

Yes, You Should Read the Instructions

What it is: The set of CMS-855 forms, distributed by the Centers for Medicare & Medicaid Services (CMS), can take hours to complete. There are seven forms in all, and even the shortest one is five pages. So, before filling out a form, ask yourself:

  • Which form(s) pertain(s) to you?
  • Who is allowed to fill out the form(s)?
  • How often and when do you update these forms?

Also, read carefully through the first pages of instruction on each form, noting the definitions of terms used. These instructions are helpful in letting you know key points like who needs to fill out each form, and how and where to submit (e.g., to a regional or geographic carrier, or national supplier clearinghouse).

855-A / 855-B: Don’t Confuse ‘Authorized’ and ‘Delegated’

The first two of the seven forms in the 855 suite are quite long: more than 45 pages each (including instructions). Here’s a brief overview of each:

  • 855-A: Providers that bill Medicare fiscal intermediaries file this form for initial enrollment, change of ownership, revalidation, voluntary billing number termination, or change of information.
  • 855-B: Healthcare suppliers that bill Medicare carriers file this form for initial enrollment, change of information, revalidation, or voluntary billing number termination.

Pitfall: Most issues with these forms arise from errors in sections 6, 15b, and 16a. Know the difference between authorized and delegated officials, and ensure that any authorized officials (15b) and delegated officials (16a) reported are also included in section 6.

855-I / 855-R: Pick the Correct Purpose

The next two forms, 855-I and 855-R, are shorter (they are 28 and 5 pages, respectively). They’re both used by individual healthcare practitioners but for different purposes.

Individual healthcare practitioners use form 855-I to report initial enrollment, change of information, revalidation or voluntary billing number deactivation. When filling out this form, ensure that only the individual practitioner signs this application, as this can never be delegated to anyone else.

If you’re an individual healthcare practitioner reassigning Medicare benefits, use form 855-R when terminating a current reassignment or adding a new one, attesting to current reassignment, or changing income reporting status.

Pitfall: Take special care with signatures and dates on form 855-R, as incorrect or missing ones are the biggest causes for returned forms.

Know When to Report 855-O, 855-S, & 855-POH

The last three forms are all relatively straightforward:

  • 855-O: Ordering or referring physicians and non-physician practitioners—those who wouldn’t normally apply to be in Medicare but can still order and refer patients for services—file this form for initial enrollment, change of information, revaluation, or voluntary billing number deactivation.
  • 855-S: Durable medical equipment suppliers—a wide umbrella that can cover entities such as department stores and oxygen suppliers—file this form for initial enrollment, reactivation or revalidation, voluntary termination, or reporting a new business location.
  • 855-POH: As a way of complying with Section 1877(i)(1)(C)(i) of the Social Security Act, this form is used for the annual reporting of physician-owned ownership or investment interest. To make things easier, if your information hasn’t changed since last submitting the report, you can complete just sections 1, 4 (if there’s a new contact person), and 5.

For those new to the CMS 855 forms, the above should give you a good head start, but Abbey recommends a further, in-depth review to be sure you’re dotting your Is and crossing your Ts—and saving yourself from wasted time. That’s exactly what he provides in his AudioSolutionz webinar “Medicare Enrolment Update for 2019.”

To join the conference or see a replay, order a DVD or transcript, or read more

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