by Scott Kraft
Get to the enrollment section of the CMS website – if you haven’t already – to download and start using the new CMS-855R enrollment form that’s used by an individual provider to reassign payments to a group practice.
CMS released the new form on December 29, 2014 but will accept either version of the reassignment form through May 31, 2015. After that date, only the new form will be accepted and the previous version will be returned to the provider.
The new form is the version that is identified in the left hand corner as (11/12). It replaces the previous version, which is identified as the (07/11) version. Of course, you also have the option of using the CMS Provider Chain Enrollment Ownership System (PECOS) to enroll your provider and reassign payments to the group practice.
The changes being made to the paper enrollment form are being synched to PECOS, CMS says.
As far as how the new form is different, the biggest change is being driven by patient convenience. Physicians and other providers can identify the location(s) within a group practice where they work the most. CMS can then communicate this information to prospective patients looking for a provider.
With group practices becoming bigger and more far flung, the change makes it easier to identify the providers within a group practice that are more likely to work at a location that is closer to the patient.
The address furnished by the physician or other provider must be one that is listed on the group practice’s enrollment as a current practice location. As a result, if the group practice has not updated its enrollment information recently or been asked to revalidate, a new location that is not on file with CMS may be rejected as a primary location for a provider within the group.
The CMS-855R is not the most complicated of the CMS enrollment forms – in fact, it is considerably easier to complete than the CMS-855B used to register a group practice or the CMS-855I that is used to register an individual provider. Its purpose is mostly to build a bridge between those enrollment forms, so that the enrolled individual is appropriately linked to the old group.
Also, remember that when a physician leaves a group practice, one step that many practices overlook is the termination of the CMS-855R relationship for that provider. This task is also done via the CMS-855R, by checking the termination box on page 2 of the form.
A provider who goes from one practice to another won’t necessarily be stopped from enrolling and reassigning payments to his or her new group if the previous CMS-855R is not revoked. In some instances, the previous practice may use the existing reassignment to hire a temporary locum tenens provider while it recruits a replacement.
However, allowing an out-of-date CMS-855R to remain in force for a long period of time does create compliance risks for the provider, who will appear to be billing to two different locations, as well as the old group practice, which will find itself with potentially unwieldy and old enrollment information when it comes time to revalidate.