The publication of the Patient
Protection and Affordable Care Act (PPACA), section 6405 -
"Physicians Who Order Items or Services Required to be Medicare
Enrolled Physicians or Eligible Professionals" (regulation CMS
6010-F), contains a requirement for certain physicians and
non-physician practitioners to enroll in the Medicare program for
the sole purpose of ordering or referring items or services for
Medicare beneficiaries. The PPACA has an effective date applicable
to written orders and certifications made on or after July 1, 2010.
The CMS 855O allows a physician to receive a Medicare
identification number (without being approved for billing
privileges) for the sole purpose of ordering and referring Medicare
beneficiaries to Medicare approved providers and suppliers. This
new Medicare application form allows physicians who do not provide
services to Medicare beneficiaries to be given a Medicare
identification number without having to supply all the data
required for the submission of Medicare claims. It also allows the
Medicare program to identify ordering and referring physicians
without having to validate the amount of data necessary to
determine claims payment eligibility (such as banking information),
while continuing to identify the physician's credentials as valid
for ordering and referring purposes.
Currently, there are
certain payment requirements for covered Part A or Part B home
health services. Specifically, to receive payment for such
services, the provider’s claim must meet all of the following
requirements: ● The ordering/certifying physician must be
identified by his or her legal name and National Provider
Identifier (NPI) on the claim. ● The ordering/certifying physician
must be enrolled in Medicare in an approved status or have validly
opted-out of the Medicare program. Section 3708 of the CARES Act
expanded who may certify the need for home health services to
include Nurse Practitioners (NPs), Clinical Nurse Specialists
(CNSs), and Physician Assistants (PAs) in order to provide
additional flexibilities to respond effectively to the serious
public health threats posed by the spread of the 2019 Novel
Coronavirus (COVID-19). The interim final rule Additional Policy
and Regulatory Revisions in Response to the COVID-19 Public Health
Emergency (RIN: 0938-AU32) includes a provision to allow NPs, CNSs
and PAs to certify the need for home health services to align with
the CARES Act. This, in turn, would require these three
non-physician practitioner (NPP) types to be enrolled in or
opted-out of Medicare to certify such services. Physicians and
practitioners complete the Medicare Enrollment Application -
Registration For Eligible Ordering and Referring Physicians and
Non-Physician Practitioners (OMB control number: 0938-1135) if they
are enrolling in Medicare solely to order, or certify certain
Medicare items and services. Based on our internal data, we
generally estimate that approximately 5,000 currently unenrolled or
non-opted out NPs, CNSs, and PAs will elect to enroll in or opt-out
of Medicare solely for the purpose of certifying home health
services in the initial year and 1,000 new NPs, CNSs, and PAs each
year will enroll in or opt-out of Medicare for the same purpose.
These additional burden estimates require a revision to the
currently approved information collection request (ICR). As the
current COVID-19 crisis expands, there is a need for flexibility of
health care services provided to Medicare beneficiaries. Expanding
who can certify home health services reduces burden on the
physicians, who up until now, were the only provider type eligible
to certify home health services. The expedited clearance of the
Medicare Enrollment Application is critical to ensuring
beneficiaries receive access to needed care while reducing the
burden on physicians. Therefore, we ask that OMB consider the
emergency clearance process to allow NPs, CNSs and PAs to certify
the need for home health services to align with the CARES Act.
As previously explained, under
section 3708 of the CARES Act, we are expanding § 424.507(b)(1) to
allow NPs, CNSs, and PAs to certify the need for home health
services. This will require the completion of the CMS-855O
application. The number of respondents associated with initial
enrollment application requirements has increased by 8,000
respondents (from 28,000 to 36,000 NPPs). Therefore, the burden
hours have increased. No revisions have been made to the Changes of
Enrollment Information and Reporting of Voluntary Withdrawal
requirements.
$1,300,000
No
No
No
Yes
No
No
Yes
Jamaa Hill 301 492-4190
No
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.
Form CMS-855O Reporting Voluntary Withdrawal of Registration Information
CMS-855O - Emergency Summary for OMB.docx
Reporting Voluntary Withdrawal of Registration Information