Avoiding Rejected Applications – Correct Form Version?

Baker Donelson
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For providers and suppliers that utilize the Medicare enrollment application forms, in lieu of Internet PECOS, it is important to confirm the current version of each form prior to its completion and submission. This can be particularly important when completing forms in advance of a pending transaction or the opening of a new business, especially when delays affect timing for submitting the application packet.

For example, effective January 1, 2017, CMS requires the use of the May 2016 version of the CMS 855S form.

In a recent MLNMatters publication, CMS advised that after December 31st, the MAC would have to return any application in which the prior, January 2013 version of the CMS 855S form had been completed.  Under CMS’s guidance in Section 15.8.1 of the Medicare Program Integrity Manual, a returned application is considered to be a non-application and no logging & tracking record is to be created by the MAC.  In essence, there would be no record of the submission at all.  Most importantly, the delay in completing and submitting an application on the correct form could result in an effective date determination that results in lost revenue.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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