Medicare CMS-855 A Application Process

In a communication last week from the Centers for Medicare and Medicaid Services (CMS) to the American Health Care Association (AHCA), CMS outlines a number of measures being taken to address noted deficiencies in the Medicare CMS-855 A process.  AHCA’s earlier request for CMS action focused on the following areas:

  • Improve the Medicare CMS-855 A application process by creating separate Medicare forms for changes of ownership and information for initial enrollments,
  • Host webinars for Medicare Administrative Contractors  (MACs) and providers with easy to follow instructions from one source,
  • Improve the overall Medicare enrollment process by requiring the MACs to follow a consistent set of guidelines and to require them to follow CMS guidance,
  • Require the MACs to confirm application receipt; provide a contact person, and create an Internet-based electronic filing and tracking tool.

Comments provided by CMS indicate that they have made significant strides in addressing each of these issues.  Reproduced below are the responses from CMS:

Application Process Improvements

Shortly after our initial meeting, CMS formed a workgroup consisting of representatives from AHCA, CMS, and several MACs. The goal of the workgroup was to develop an easy-to-follow CMS-855A completion guide.  As a direct result Guidance on Completing the CMS-855A Enrollment Form (MLN SE1135) was developed and issued to providers and suppliers via our listserv.  The Guidance document is available on the CMS website and we have attached a PDF copy for your reference.  You will be pleased to know that we have received favorable feedback on this document.  We appreciated the opportunity to collaborate with AHCA on its development and finalization.

In order to keep AHCA members up-to-date on changes in the Medicare program, CMS offers a free email subscription service, which allows CMS.HHS.gov users to receive notifications by e-mail when new information is available. With a subscription profile, you get the updated information on the items of interest to you automatically without having to return to the website and check for changes.  The sign up process is easy.  To sign up and review additional information about CMS publications, please click here.

Webinars, Provider and MAC Training

AHCA also recommended that CMS host training webinars.  We are working on the development of a webinar series for the provider community on provider enrollment and how to complete both paper and internet-based PECOS web based applications.  To make these sessions effective, separate sessions will be held for different provider/supplier types — for example providers/suppliers who complete the CMS-855A would attend a session; provider/suppliers who complete a CMS-855 I would attend a separate session.  We expect to have the planning complete shortly and the sessions to occur in mid-to-late summer of this year.  We would hope you will assist us in urging your members – as well as non-members — to attend one or more of these one-hour training sessions.

Improving the Consistency CMS guidelines between MACs

Medicare contractors are required to follow all Medicare provider enrollment guidelines and regulations.  However acknowledging your concerns, as well as those of other providers, you will be pleased to know that the management and staff of PEOG now have several regularly scheduled interactive monthly meetings with all MACs.  During these meetings we clarify the intent of recently issued guidelines as well as existing guidelines to ensure there is a common understanding across MACs.  You should also know that each MAC also has a single point of contact within PEOG should they need any assistance or clarification at any time.

Acknowledgment of Application Receipt

We recognize the concerns of AHCA involve not only the need to make the provider enrollment process simpler, but the need for CMS to expedite processing of the application.  Toward that end, AHCA’s comments and those of many other providers and suppliers have been taken into consideration as we move to make major improvements to our internet-based PECOS provider enrollment application process.  Again, we are pleased that members of the AHCA participate in our quarterly Provider Focus Group meetings.  This personal interaction and involvement gives us invaluable input as we move to improve the provider enrollment process.

The use of the internet-based PECOS application submission is streamlined and these applications can be processed in less time and with greater accuracy than an application submitted using a paper application form.  When submitted through internet-based PECOS, receipt of the application is immediately acknowledged and the status of the application can be tracked as it progresses.  Further, just this month, qualified providers and suppliers have the option to electronically sign their enrollment application.

We recognize AHCA members may be frustrated with the length of time it takes to become fully enrolled in the Medicare program as it is a lengthy process.  During the Workgroup sessions the participants discussed the fact that many applicants are not aware that the provider enrollment process involves not only the MACs, but the Regional Offices Survey and Certification Divisions as well as each State Agency.  The Workgroup recommended the development of further information on the enrollment lifecycle for providers who complete the CMS-855A.  Please look for more information on this issue in an upcoming update to the CMS-855A Guidance mentioned earlier.

CMS-855 A

While we strongly urge all providers to use internet-based PECOS to submit an enrollment application, we recognize that many providers will continue to use the CMS-855A paper form.  We are continuing to work toward the simplification of all of the application forms in the CMS-855 form series and expect to have a new revision available in early 2013.  In accordance with federal requirements, the CMS-855A form revision will be published in the federal register for comment prior to finalization.  We urge your members to review the proposed changes and comment prior to the close of the comment period.  However, please know that if at any time AHCA members find sections of the current (or revised) CMS-855A particularly challenging or otherwise problematic, please let us know.  We can certainly work to clarify and/or provide appropriate guidance.

During our February 17, 2012 meeting you also requested clarification of the definition of adverse action.  Accordingly, adverse action includes one or more of the following (1) a Medicare-imposed revocation of any Medicare billing privilege; (2) suspension or revocation of a license to provider heath care by any State licensing authority (3) revocation or suspension by an accreditation organization (4) a conviction  of a Federal or State felony offense (as defined CFR 42 424.535 (a)(3)(i) ) within the last 10 years preceding enrollment, revalidation, or re-enrollment or (5) an exclusion or debarment from participation in a Federal or State health care program.