Changes of Information and Complete Form CMS-855 Applications
A provider must submit a complete Form CMS-855 application if it (1) submits any change request, and (2) does not have an established enrollment record in the Provider Enrollment, Chain and Ownership System (PECOS). (For purposes of this requirement, the term “change request” includes electronic funds transfer (EFT) changes.)
It is immaterial (1) whether the provider or another party (e.g., local government changes street name) was responsible for triggering the changed data; or (2) the signer of the change request or EFT form already has a signature on file with the contractor. If the contractor receives a change request from a provider that is not in PECOS, the contractor shall develop for the entire application in accordance with the procedures described in this chapter (i.e., the contractor shall treat the transaction as a request for additional information).
Consistent with existing policies for requesting additional data, the provider has 30 calendar days from the date of the contractor’s request to furnish a complete Form CMS-855. During this period, the contractor should “hold” (i.e., not process) the change request until the entire application arrives; no logging and tracking (L & T) record shall be created in PECOS at this point. If the provider fails to submit a complete application within the aforementioned 30-day period, the contractor shall follow the instructions in section 15.10.1.2(B) of this chapter. If the provider submits the application, the contractor shall process it in accordance with the instructions in this chapter and all other applicable CMS directives.
This includes:
• Processing the complete application consistent with the timeframes for initial applications in section 15.6.1 of this chapter.
• Ensuring that all data elements on the Form CMS-855 have been validated, as it would with an initial enrollment application. The contractor shall not approve the change request until all data on the complete Form CMS-855 has been validated.
• Creating an L & T record and enrollment record in PECOS prior to approving
the change request. (The receipt date should be the date on which the complete application was received, not the date on which the initial change request was received.) The transaction should be treated as an initial enrollment in PECOS; internally, the contractor shall treat it as a change of information. As the complete application will presumably incorporate the changed data reported on the original Form CMS-855 change request, the contractor shall not take two separate counts (one initial and one change request) for the transaction.
Incomplete or Unverifiable Changes of Information
The contractor shall follow the instructions in this section 15.10.1.2 if a submitted change request cannot be processed to completion.
A. Provider Has an Established
Enrollment Record in the Provider Enrollment, Chain and Ownership System (PECOS) Assume that a provider with a PECOS enrollment record submits a Form CMS-855 change request and (1) fails to timely respond to the contractor’s request for additional or clarifying information, or (2) the changed information cannot be validated. The contractor shall reject the change request in accordance with section 15.8.2 of this chapter. Moreover, if the changed information is of such materiality that the contractor cannot determine whether the provider still meets all enrollment requirements, the contractor shall refer the matter to its Provider Enrollment Integrity Group (PEOG) liaison for guidance. (For instance, if the data involves a change in the provider’s lone practice location and the contractor cannot verify the validity of the new site, this clearly raises questions as to the provider’s continued compliance with Medicare requirements.)
B. Provider is Not in PECOS
As stated in section 15.10.1.1 of this chapter, if a provider does not have an established enrollment record in PECOS and wants to change any of its existing enrollment or electronic funds transfer (EFT) information, it must submit a complete Form CMS-855 before the contractor can effectuate the change. If the provider fails to submit the completed form within the applicable 30-day period, the contractor shall request that the provider revalidate its Medicare enrollment information per 42 CFR §424.515.
Special Instructions for Certified Providers, ASCs, and Portable X-ray Suppliers
A. Timeframe for Regional Office (RO)
Approval In situations where RO approval of the change of information is required, it is strongly recommended that the contractor advise the provider that it may take 6 months (or longer) for the request to be approved. The manner and timing in which this information is relayed lies solely within the contractor’s discretion.
B. Post-Recommendation
Changes If an applicant submits a change request after the contractor makes a recommendation on the provider’s initial CMS-855 application but before the RO issues a tie-in/approval notice, the contractor shall process the newly-submitted data as a separate change of information; it shall not take the changed information/corrected pages and, immediately upon receipt, send them directly to the State/RO to be incorporated into the existing application.
The contractor, however, need not enter the change request into the Provider Enrollment, Chain and Ownership System (PECOS) until the tie-in notice is issued. In entering the change request into PECOS, the contractor shall use the date it received the change request in its mailroom as the actual receipt date in PECOS; the date the tiein notice was issued shall not be used. The contractor shall explain the situation in the “Comments” section in PECOS and in the provider file.
C. Hospital Addition of Practice Location
In situations where a hospital is adding a practice location, the contractor shall notify the provider in writing that its recommendation for approval does not constitute approval of the facility or group as provider-based under 42 CFR § 413.65.
D. Recommendation
Before New HHA Location Established If an HHA is adding a branch or changing the location of its main location or an existing branch, the contractor may make a recommendation for approval to the State/RO prior to the establishment of the new/changed location (notwithstanding any other instruction in this chapter to the contrary). If the contractor opts to make such a recommendation prior to the establishment of the new/changed location, it shall note in its recommendation letter that the HHA location has not yet moved or been established.
Voluntary Terminations
Voluntary terminations shall be processed in accordance with the timeframes in section 15.6.2, et al. of this chapter. If the termination involves a certified provider or certified supplier, the contractor may terminate the entity without making a recommendation to the State and Regional Office (RO).
Within 3 business days after the contractor finishes processing the termination, however, it shall notify the State and RO of this via letter, e-mail, or fax. Upon receipt of a voluntary termination, the contractor may ask the provider to complete the “Special Payments” portion of section 4 of the Form CMS-855 so that future payments can be sent thereto.
If the provider has no special payments address already on file, the addition should be included in the same transaction as the termination (i.e., one transaction incorporating both items). If the provider wants to change its existing special payments address, the transaction should be treated as a separate change request (i.e., one termination and one change request).
The provider is not required to submit a Form CMS-588 in conjunction with a termination. When processing a voluntary termination of a reassignment, the contractor shall contact the group to confirm that: (1) the group member PTAN is being terminated from all locations; and (2) if multiple group member PTANs exist for multiple group locations, each PTAN is terminated. However, if a group has one PTAN with multiple addresses, the contractor need not contact the group to confirm the termination.
Electronic Fund Transfers (EFT)
A. General Information
If a provider does not have an established enrollment record in the Provider Enrollment, Chain and Ownership System (PECOS) and wants to change any of its EFT information (e.g., bank routing number), it must submit a complete Form CMS-855 before the contractor can effectuate the change. With the exception of the situation described in section (B) below, it is immaterial whether the provider or the bank was responsible for triggering the changed data. Under 42 CFR §424.510(d)(2)(iv) and §424.510(e):
• All providers (including Federal, State and local governments) enrolling in Medicare must use EFT in order to receive payments. Moreover, any provider not currently on EFT that (1) submits any change to its existing enrollment data or (2) submits a revalidation application must also submit a Form CMS-588 and thereafter receive payments via EFT.
• If a provider is already receiving payments via EFT and is located in a jurisdiction that is undergoing a change of Medicare contractors, the provider must continue to receive payments via EFT. However, the change in contractors does not require the provider to submit a new Form CMS-588 unless CMS states otherwise.
B. Verification
Providers and suppliers may submit a Form CMS-588 via paper or through PECOS. In either case, the contractor shall ensure that:
• The information submitted on the Form CMS-588 is complete and accurate.
• The provider/supplier submitted (1) a voided check or (2) a letter from the bank verifying the account information.
• The routing number and account number matches what was provided on the Form CMS-588.
• The signature is valid. (NOTE: For electronic Form CMS-588 submissions, the provider can either e-sign the form or submit a written signature via the paper Form CMS-588)
Once the Form CMS-588 has been processed, the 588 form will be printed and delivered to the contractor’s financial area along with the voided check and letter from the bank verifying account information, for proper processing of the EFT information. If this information cannot be verified and the provider fails to timely respond to a developmental request, the contractor shall reject the Form CMS-588 and, if applicable, the accompanying Form CMS-855.
C. Miscellaneous Policies
1. Banking Institutions - All payments must be made to a banking institution. EFT payments to non-banking institutions (e.g., brokerage houses, mutual fund families) are not permitted. If the provider’s bank of choice does not or will not participate in the provider’s proposed EFT arrangement, the provider must select another financial institution.
2. Verification - The contractor shall ensure that all EFT arrangements comply with CMS Publication 100-04, chapter 1, section 30.2.5.
3. Sent to the Wrong Unit - If a provider submits an EFT change request to the contractor but not to the latter’s enrollment unit, the recipient unit shall forward it to the enrollment staff, which shall then process the change. The enrollment unit is responsible for processing EFT changes. As such, while it may send the original EFT form back to the recipient unit, the enrollment unit shall keep a copy of the EFT form and append it to the provider’s Form CMS-855 in the file.
4. Comparing Signatures - If the contractor receives an EFT change request, it shall compare the signature thereon with the same official’s signature on file to ensure that it is the same person. If the person’s signature is not on file, the contractor shall request that he/she complete section 6 of the Form CMS-855 and furnish his/her signature in section 15 or 16. (This shall be treated as part of the EFT change request for purposes of timeliness and reporting.)
5. Bankruptcies and Garnishments – If the contractor receives a copy of a court order to send payments to a party other than the provider, it shall contact the applicable RO’s Office of General Counsel.
6. Closure of Bank Account – If a provider has closed its bank/EFT account but will remain enrolled in Medicare, the contractor shall place the provider on payment withhold until an EFT agreement (and Form CMS-855, if applicable) is submitted and approved by the contractor. If such an agreement is not submitted within 90 days after the contractor learned that the account was closed, the contractor shall commence revocation procedures in accordance with the instructions in this chapter. The basis for revocation would be §424.535(a) due to the provider’s failure to comply with the EFT requirements outlined in §424.510(e)(1) and (e)(2).
7. Reassignments – If a physician or non-physician practitioner is reassigning all of his/her benefits to another supplier and the latter is not currently on EFT, neither the practitioner nor the reassignee needs to submit a Form CMS-588. This is because (1) the practitioner is not receiving payment directly, and (2) accepting a reassignment does not qualify as a change of information request. If, however, the group later submits a change of information request and is not on EFT, it must submit a Form CMS-588.
8. Final Payments – If a non-certified supplier (e.g., physician, ambulance company) voluntarily withdraws from Medicare and needs to obtain its final payments, the contractor shall send such payments to the provider's EFT account of record. If the account is defunct, the contractor can send payments to the provider’s “special payments” address or, if none is on file, to any of the provider’s practice locations on record. If neither the EFT account nor the aforementioned addresses are available, the provider shall submit a Form CMS-855 or Form CMS-588 request identifying where it wants payments to be sent.
9. Chain Organizations - Per CMS Publication 100-04, chapter 1, section 30.2, a chain organization may have payments to its providers be sent to the chain home office. However, any mass EFT changes (involving large numbers of chain providers) must be submitted and processed in the same fashion as any other change in EFT data. For instance, if a chain has 100 providers and each wants to change its EFT account to that of the chain home office, 100 separate Form CMS-588s must be submitted. If any of the chain providers have never completed a Form CMS-855 before, they must do so at that time.
A provider must submit a complete Form CMS-855 application if it (1) submits any change request, and (2) does not have an established enrollment record in the Provider Enrollment, Chain and Ownership System (PECOS). (For purposes of this requirement, the term “change request” includes electronic funds transfer (EFT) changes.)
It is immaterial (1) whether the provider or another party (e.g., local government changes street name) was responsible for triggering the changed data; or (2) the signer of the change request or EFT form already has a signature on file with the contractor. If the contractor receives a change request from a provider that is not in PECOS, the contractor shall develop for the entire application in accordance with the procedures described in this chapter (i.e., the contractor shall treat the transaction as a request for additional information).
Consistent with existing policies for requesting additional data, the provider has 30 calendar days from the date of the contractor’s request to furnish a complete Form CMS-855. During this period, the contractor should “hold” (i.e., not process) the change request until the entire application arrives; no logging and tracking (L & T) record shall be created in PECOS at this point. If the provider fails to submit a complete application within the aforementioned 30-day period, the contractor shall follow the instructions in section 15.10.1.2(B) of this chapter. If the provider submits the application, the contractor shall process it in accordance with the instructions in this chapter and all other applicable CMS directives.
This includes:
• Processing the complete application consistent with the timeframes for initial applications in section 15.6.1 of this chapter.
• Ensuring that all data elements on the Form CMS-855 have been validated, as it would with an initial enrollment application. The contractor shall not approve the change request until all data on the complete Form CMS-855 has been validated.
• Creating an L & T record and enrollment record in PECOS prior to approving
the change request. (The receipt date should be the date on which the complete application was received, not the date on which the initial change request was received.) The transaction should be treated as an initial enrollment in PECOS; internally, the contractor shall treat it as a change of information. As the complete application will presumably incorporate the changed data reported on the original Form CMS-855 change request, the contractor shall not take two separate counts (one initial and one change request) for the transaction.
Incomplete or Unverifiable Changes of Information
The contractor shall follow the instructions in this section 15.10.1.2 if a submitted change request cannot be processed to completion.
A. Provider Has an Established
Enrollment Record in the Provider Enrollment, Chain and Ownership System (PECOS) Assume that a provider with a PECOS enrollment record submits a Form CMS-855 change request and (1) fails to timely respond to the contractor’s request for additional or clarifying information, or (2) the changed information cannot be validated. The contractor shall reject the change request in accordance with section 15.8.2 of this chapter. Moreover, if the changed information is of such materiality that the contractor cannot determine whether the provider still meets all enrollment requirements, the contractor shall refer the matter to its Provider Enrollment Integrity Group (PEOG) liaison for guidance. (For instance, if the data involves a change in the provider’s lone practice location and the contractor cannot verify the validity of the new site, this clearly raises questions as to the provider’s continued compliance with Medicare requirements.)
B. Provider is Not in PECOS
As stated in section 15.10.1.1 of this chapter, if a provider does not have an established enrollment record in PECOS and wants to change any of its existing enrollment or electronic funds transfer (EFT) information, it must submit a complete Form CMS-855 before the contractor can effectuate the change. If the provider fails to submit the completed form within the applicable 30-day period, the contractor shall request that the provider revalidate its Medicare enrollment information per 42 CFR §424.515.
Special Instructions for Certified Providers, ASCs, and Portable X-ray Suppliers
A. Timeframe for Regional Office (RO)
Approval In situations where RO approval of the change of information is required, it is strongly recommended that the contractor advise the provider that it may take 6 months (or longer) for the request to be approved. The manner and timing in which this information is relayed lies solely within the contractor’s discretion.
B. Post-Recommendation
Changes If an applicant submits a change request after the contractor makes a recommendation on the provider’s initial CMS-855 application but before the RO issues a tie-in/approval notice, the contractor shall process the newly-submitted data as a separate change of information; it shall not take the changed information/corrected pages and, immediately upon receipt, send them directly to the State/RO to be incorporated into the existing application.
The contractor, however, need not enter the change request into the Provider Enrollment, Chain and Ownership System (PECOS) until the tie-in notice is issued. In entering the change request into PECOS, the contractor shall use the date it received the change request in its mailroom as the actual receipt date in PECOS; the date the tiein notice was issued shall not be used. The contractor shall explain the situation in the “Comments” section in PECOS and in the provider file.
C. Hospital Addition of Practice Location
In situations where a hospital is adding a practice location, the contractor shall notify the provider in writing that its recommendation for approval does not constitute approval of the facility or group as provider-based under 42 CFR § 413.65.
D. Recommendation
Before New HHA Location Established If an HHA is adding a branch or changing the location of its main location or an existing branch, the contractor may make a recommendation for approval to the State/RO prior to the establishment of the new/changed location (notwithstanding any other instruction in this chapter to the contrary). If the contractor opts to make such a recommendation prior to the establishment of the new/changed location, it shall note in its recommendation letter that the HHA location has not yet moved or been established.
Voluntary Terminations
Voluntary terminations shall be processed in accordance with the timeframes in section 15.6.2, et al. of this chapter. If the termination involves a certified provider or certified supplier, the contractor may terminate the entity without making a recommendation to the State and Regional Office (RO).
Within 3 business days after the contractor finishes processing the termination, however, it shall notify the State and RO of this via letter, e-mail, or fax. Upon receipt of a voluntary termination, the contractor may ask the provider to complete the “Special Payments” portion of section 4 of the Form CMS-855 so that future payments can be sent thereto.
If the provider has no special payments address already on file, the addition should be included in the same transaction as the termination (i.e., one transaction incorporating both items). If the provider wants to change its existing special payments address, the transaction should be treated as a separate change request (i.e., one termination and one change request).
The provider is not required to submit a Form CMS-588 in conjunction with a termination. When processing a voluntary termination of a reassignment, the contractor shall contact the group to confirm that: (1) the group member PTAN is being terminated from all locations; and (2) if multiple group member PTANs exist for multiple group locations, each PTAN is terminated. However, if a group has one PTAN with multiple addresses, the contractor need not contact the group to confirm the termination.
Electronic Fund Transfers (EFT)
A. General Information
If a provider does not have an established enrollment record in the Provider Enrollment, Chain and Ownership System (PECOS) and wants to change any of its EFT information (e.g., bank routing number), it must submit a complete Form CMS-855 before the contractor can effectuate the change. With the exception of the situation described in section (B) below, it is immaterial whether the provider or the bank was responsible for triggering the changed data. Under 42 CFR §424.510(d)(2)(iv) and §424.510(e):
• All providers (including Federal, State and local governments) enrolling in Medicare must use EFT in order to receive payments. Moreover, any provider not currently on EFT that (1) submits any change to its existing enrollment data or (2) submits a revalidation application must also submit a Form CMS-588 and thereafter receive payments via EFT.
• If a provider is already receiving payments via EFT and is located in a jurisdiction that is undergoing a change of Medicare contractors, the provider must continue to receive payments via EFT. However, the change in contractors does not require the provider to submit a new Form CMS-588 unless CMS states otherwise.
B. Verification
Providers and suppliers may submit a Form CMS-588 via paper or through PECOS. In either case, the contractor shall ensure that:
• The information submitted on the Form CMS-588 is complete and accurate.
• The provider/supplier submitted (1) a voided check or (2) a letter from the bank verifying the account information.
• The routing number and account number matches what was provided on the Form CMS-588.
• The signature is valid. (NOTE: For electronic Form CMS-588 submissions, the provider can either e-sign the form or submit a written signature via the paper Form CMS-588)
Once the Form CMS-588 has been processed, the 588 form will be printed and delivered to the contractor’s financial area along with the voided check and letter from the bank verifying account information, for proper processing of the EFT information. If this information cannot be verified and the provider fails to timely respond to a developmental request, the contractor shall reject the Form CMS-588 and, if applicable, the accompanying Form CMS-855.
C. Miscellaneous Policies
1. Banking Institutions - All payments must be made to a banking institution. EFT payments to non-banking institutions (e.g., brokerage houses, mutual fund families) are not permitted. If the provider’s bank of choice does not or will not participate in the provider’s proposed EFT arrangement, the provider must select another financial institution.
2. Verification - The contractor shall ensure that all EFT arrangements comply with CMS Publication 100-04, chapter 1, section 30.2.5.
3. Sent to the Wrong Unit - If a provider submits an EFT change request to the contractor but not to the latter’s enrollment unit, the recipient unit shall forward it to the enrollment staff, which shall then process the change. The enrollment unit is responsible for processing EFT changes. As such, while it may send the original EFT form back to the recipient unit, the enrollment unit shall keep a copy of the EFT form and append it to the provider’s Form CMS-855 in the file.
4. Comparing Signatures - If the contractor receives an EFT change request, it shall compare the signature thereon with the same official’s signature on file to ensure that it is the same person. If the person’s signature is not on file, the contractor shall request that he/she complete section 6 of the Form CMS-855 and furnish his/her signature in section 15 or 16. (This shall be treated as part of the EFT change request for purposes of timeliness and reporting.)
5. Bankruptcies and Garnishments – If the contractor receives a copy of a court order to send payments to a party other than the provider, it shall contact the applicable RO’s Office of General Counsel.
6. Closure of Bank Account – If a provider has closed its bank/EFT account but will remain enrolled in Medicare, the contractor shall place the provider on payment withhold until an EFT agreement (and Form CMS-855, if applicable) is submitted and approved by the contractor. If such an agreement is not submitted within 90 days after the contractor learned that the account was closed, the contractor shall commence revocation procedures in accordance with the instructions in this chapter. The basis for revocation would be §424.535(a) due to the provider’s failure to comply with the EFT requirements outlined in §424.510(e)(1) and (e)(2).
7. Reassignments – If a physician or non-physician practitioner is reassigning all of his/her benefits to another supplier and the latter is not currently on EFT, neither the practitioner nor the reassignee needs to submit a Form CMS-588. This is because (1) the practitioner is not receiving payment directly, and (2) accepting a reassignment does not qualify as a change of information request. If, however, the group later submits a change of information request and is not on EFT, it must submit a Form CMS-588.
8. Final Payments – If a non-certified supplier (e.g., physician, ambulance company) voluntarily withdraws from Medicare and needs to obtain its final payments, the contractor shall send such payments to the provider's EFT account of record. If the account is defunct, the contractor can send payments to the provider’s “special payments” address or, if none is on file, to any of the provider’s practice locations on record. If neither the EFT account nor the aforementioned addresses are available, the provider shall submit a Form CMS-855 or Form CMS-588 request identifying where it wants payments to be sent.
9. Chain Organizations - Per CMS Publication 100-04, chapter 1, section 30.2, a chain organization may have payments to its providers be sent to the chain home office. However, any mass EFT changes (involving large numbers of chain providers) must be submitted and processed in the same fashion as any other change in EFT data. For instance, if a chain has 100 providers and each wants to change its EFT account to that of the chain home office, 100 separate Form CMS-588s must be submitted. If any of the chain providers have never completed a Form CMS-855 before, they must do so at that time.
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