• Prior Version of 855 Forms Accepted Through October 2011
  • September 1, 2011 | Author: Christina Ann Gonzalez
  • Law Firm: King & Spalding LLP - Houston Office
  • The Centers for Medicare and Medicaid Services (CMS) has announced that although providers and suppliers should begin using the recently revised versions of the Medicare Provider-Supplier Enrollment Applications (CMS-855) now, the 2008 versions may be used through October 2011. Providers and suppliers enrolling for the sole purpose to order and refer must use the new CMS-855O form immediately.

    The changes that providers will see to the revised 855A include the following:

    • A provider that is a physician-owned hospital must report that physician ownership and must complete a separate Attachment to the 855A that requires information to be completed for every organization and individual that has any percentage of ownership or investment interest in the provider.
    • Providers must now list cost report year end date.
    • Section 5 (“Ownership Interest and/or Managing Control Information (Organizations)”) now requires an organizational diagram identifying all of the entities listed in the section and their relationships with the provider and with each other. If the provider is a skilled nursing facility (SNF), a diagram must be provided that identifies the organizational structures of all of the SNF’s owners, including owners that were not required to be listed in Section 5 or in Section 6.
    • Providers must list the exact percentage of ownership or control interest in the provider that the owning/managing organizations listed in Section 5 have.
    • Section 5 also specifically states that “all entities with at least a five percent mortgage, deed of trust, or other security interest in the provider” must be reported.
    • Section 6 (“Ownership Interest and/or Managing Control Information (Individuals)”) also now requires that percentage of interest in the provider be reported, as well as the listed individual’s place of birth.
    • If any of the organizations or individuals in Sections 5 or 6, respectively, provide contracted services to the provider, the types of services furnished must be described.
    • Whereas the prior version of the 855A required that any organization or individual that had a partnership interest in the provider, regardless of the percentage of ownership, be listed in Section 5 or 6, the revised 855A specifies that for limited partnerships, limited partners must be reported only if their interest in the limited partnership is at least ten percent.

    Revisions to the 855R, 855I, and 855S are less extensive, and the revised CMS 855B does not include the same extensive changes and instructions to the ownership and managing control sections as with the revised 855A. The changes that suppliers will see to the revised 855B include the following:

    • Advanced Diagnostic Imaging (ADI) suppliers must provide the name of the Accrediting Organization that accredited the supplier’s ADI Modality. This change is also included in the revised 855I.

    • Unlike the revised 855A, the revised 855B still requires suppliers to list any organization or individual with a partnership interest in the supplier, regardless of the percentage of ownership the partner has.
    • Individuals listed in Section 6 must also include their state and country of birth.