By Brian Banks

It’s no joke: Eighty percent of the enrollment documentation received by the National Supplier Clearinghouse (NSC) has missing or incomplete information, leading to long delays in how soon an O&P facility can start seeing Medicare patients. This high failure rate is despite the release of a revised enrollment form (CMS 855S) that has simpler instructions designed to make completing the form more straightforward.

O&P facilities that know how to provide accurate and complete information on the CMS 855S will decrease processing time, get supplier numbers quickly and avoid any break in service to Medicare patients. Eliminating unnecessary requests for information makes for a much more efficient process for a facility and the NSC.

Below are some of the recurring issues NSC analysts find when processing the revised CMS 855S, along with helpful hints for completing the revised form properly.

1.    Not reporting the NPI or not providing a copy of NPI notification.

The Health Insurance Portability and Accountability Act of 1996 (HIPAA) mandated that all HIPAA-covered health care providers, whether individuals or organizations, must use a standard, unique health identifier to identify themselves in HIPAA transactions. In January 2004, the Health and Human Services Secretary adopted the National Provider Identifier (NPI) as this identifier.

While the deadline for using the NPI in transactions is several months away, the revised CMS 855S requires practices to submit their NPI along with a copy of the notification letter provided by the NPI enumerator. The NSC has examples of acceptable NPI notifications on its Web site (www.palemttogba.com) under the Supplier Enrollment/Initial Enrollment folder.

Suppliers should list their NPI in Section 1B and submit a copy of the notification verifying the NPI with all enrollment documentation.

The NPI is also location-specific. Therefore, the address listed on the NPI notification must match the physical address of the business. Further, Medicare regulations require suppliers to obtain an NPI for each physical location, not each tax identification number.

If you are unable to locate your NPI notification, you may contact the National Plan and Provider Enumeration System (NPPES) at (800) 465-3203 or e-mail customerservice@npienumerator.com.

Applying for the NPI is a separate process from Medicare enrollment. To obtain an NPI, you may apply online at https://NPPES.cms.hhs.gov. For more information about NPI enumeration, visit www.cms.hhs.gov/NationalProvIdentStand.

2.    Not including the EFT agreement when submitting a new application.

When initially enrolling or when submitting an application for an additional location, suppliers must complete and submit the Authorization Agreement for Electronic Funds Transfer (form CMS 588).

The NSC does not process or enroll suppliers into the EFT program, but does verify that the correct Medicare fee-for-service contractor has been listed and ensure the agreement is completed and signed properly. The NSC will send the agreements to that contractor for processing.

Consequently, suppliers must submit a separate form for each Medicare fee-for-service contractor for the DME MAC where it submits claims. Each form must include a voided check, preprinted deposit slip or confirmation of account information on bank letterhead.

Suppliers should list the proper Medicare contractor on the form and ensure that it is signed by the person at the facility who is the authorized or delegated official for Medicare.

Any changes to EFT information should be submitted directly to the appropriate Medicare fee-for-service contractor.

3.    Not listing a managing employee for each location.

The instructions for Section 6 of the form require that each supplier have at least one managing employee.

A managing employee is any individual, including a general manager, business manager or administrator, who exercises operational or managerial control over the supplier or who conducts the supplier’s day-to-day operations.

Suppliers should report all managing employees in this section.

4.    Putting the wrong number in Section 1B (Medicare Identification Number).

There seems to be some confusion as to what Medicare identification number should be reported in Section 1B. Suppliers should list their NPI number, but they should also list their supplier number (often called the Medicare Identification Number) if it has been issued. This will help the NSC ensure the enrollment documentation is processed for the correct supplier.

If suppliers are enrolled in Medicare programs other than the DMEPOS program, they should report this information in Section 2A4.

These four areas are where most suppliers fail to complete the revised CMS 855S form correctly. Save yourself time and effort by providing accurate and complete information to the NSC.

Brian Banks is NSC Ombudsman for Palmetto GBA.