Tuesday 18 October 2016

Processing Alternatives – Form CMS-855A

A. General Processing Alternatives 

The following general alternatives are applicable to all sections of the Form CMS- 855A, unless otherwise specified:
1. Information Disclosed Elsewhere – If a data element on the provider’s Form CMS- 855A application is missing but the information is disclosed (1) elsewhere on the application or (2) in the supporting documentation submitted with the application, the contractor need not obtain the missing data via an updated Form CMS-855A page and a newly-signed certification statement; no further development – not even by telephone – is required. The following information, however, must be furnished in the appropriate section(s) of the Form CMS-855A, even if the data is identified elsewhere on the form or in the supporting documentation:

a. Any final adverse action data requested in sections 3, 5B and 6B of the Form CMS- 855A
b. All legal business names (LBNs)(e.g., provider, chain home office)
c. All tax identification numbers (TINs)(e.g., provider, owning organization)
d. NPI-legacy number combinations in section 4 of the Form CMS-855A
e. Provider type
f. The following data in sections 2F, 2G and 2H: • “Doing business as” name

• Effective dates of sale/transfer/consolidation
• Checkbox in section 2F indicating whether seller will accept assets/liabilities
• Names of units with separate legacy numbers/NPIs;
• All NPIs and legacy numbers

Data that is available on a previously submitted Form CMS-855A application or in PECOS cannot be used for purposes of this “Information Disclosed Elsewhere” exception. Also, per section 15.7.3 of this chapter, the contractor shall document in the provider file that the missing information was found elsewhere in the enrollment package.

2. Licenses - In situations where the provider is required to submit a copy of a particular professional or business license, certification, or registration but fails to do so, the contractor need not obtain such documentation from the provider if the contractor can verify the information independently. This may be done by: (1) reviewing and printing confirmation pages from the applicable state web site, (2) requesting and receiving from the appropriate state body written confirmation of the provider’s status therewith, and (3) using any other third-party verification source. Similarly, if the provider submits a copy of the applicable license, certification, or registration but fails to complete the appropriate section of the form, the section need not be completed if the data in question can be verified on the license/certification itself or via any of the three mechanisms above.

• The above-referenced written confirmation from a state body of the provider’s status can be in the form of a letter, fax, or e-mail, but it must be in writing. Documentation of a verbal conversation between the contractor and the body in question does not qualify as appropriate confirmation.

• This exception only applies to those documents that traditionally fall within the category of licenses, registrations, or certifications. It does not apply to items such as adverse action documentation, bills of sale, etc. Furthermore, the exception is moot in cases where: (1) a particular license/certification is not required by the state, or (2) the license/certification has not been obtained because a state survey has not yet been performed.

3. City, State, and ZIP Code - If an address (e.g., correspondence address, practice location) lacks a city or state, the contractor can verify the missing data in any manner it chooses. In addition, the contractor can obtain the “zip + four” from either the U.S. Postal Service or Finalist in PECOS.

B. Sectional Processing Alternatives 

The processing alternatives in this subsection B are in addition to, and not in lieu of, those in subsection A.

1. Section 1
With the exception of (1) the voluntary termination checkbox and (2) the effective date of termination, any blank data/checkboxes in section 1 can be verified through any means chosen by the contractor (e.g., e-mail, telephone, fax).

• Other than the TIN and the LBN, all information in section 2B1 can be captured by telephone, e-mail, fax, or a Web site.

• If the contractor is aware that a particular state does not require licensure/certification and the “Not Applicable” boxes in section 2B2 are not checked, no further development is needed.

• With respect to sections 2F, 2G, and 2H, if the old/new owner’s current contractor is not listed, the contractor can research this data on its own or obtain it from the provider by any means.

• In section 4A, if the “type of practice location” checkbox is blank, the contractor can confirm the information via e-mail or fax.

• In section 4B, if neither box is checked and no address is provided, the contractor can contact the provider by telephone, e-mail, or fax to confirm the provider’s intentions. If the provider replies that the “special payments” address is the same as the practice location, no further development is needed. If, however, the provider wants payments to be sent to a different address, the address in 4B must be completed via the Form CMS-855A.

• In section 4D, if the “Check here” box is not checked and no address is provided, the contractor can contact the provider by telephone, e-mail or fax to confirm the provider’s intentions. If the provider replies that the base of operations address is the same as the practice location, no further development is needed. If the provider indicates that the base of operations is at a different location, the address in 4D must be completed via the Form CMS-855A.

• In section 4E, if the vehicle certificates are furnished but the applicable CMS- 855A sections are blank, the contractor can verify via telephone, e-mail or fax that said vehicles are the only ones the provider has.

• If all of section 7 is blank (including the check box just above section 7A), no additional development is necessary.

• If the provider indicates that it is part of a chain but the checkboxes in section 7A are blank, the contractor can verify the type of transaction involved via email or fax.

• In section 7B, if the person is also listed with complete information in section 6A (e.g., the individual’s Social Security Number (SSN) is listed in section 6A1), only the individual’s first and last name need be listed in section 7B.

• In section 7C, if the entity is also listed with complete information in section 5A, the company’s legal business name is the only data that must be listed in section 7C. (If blank, the cost report date, the home office’s contractor, and the chain number can be developed by phone, e-mail, or fax.)

• If blank, data in section 7D can be collected by telephone, e-mail or fax.

• If blank, data in section 7E can be collected by e-mail or fax.

• If the telephone number is blank, the number can be verified with the provider by telephone, e-mail or fax.

• If all of section 8 is blank (including the check box), no additional development is necessary

• If it is obvious that the entity is not enrolling as a home health agency (HHA), the checkbox above section 12A can be left blank.

• If the entity is an HHA: o If section 12A1 or 12A3B is blank, the data can be verified by telephone, email, or fax. o If the telephone number in section 12B is blank, the number can be verified with the provider by telephone, e-mail or fax

• If this section is completely blank, the contractor need not develop for this information and can simply contact an authorized or delegated official.

• If neither box is checked but the contact person information is incomplete (e.g., no telephone number listed), the contractor may either (1) develop for this information by telephone, e-mail or fax, or (2) contact an authorized or delegated official.

The telephone number can be left blank. No further development is needed

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