Crosswalk

2015 CMS 855O REVISIONS
Section
Number

Change

Reason

Entire 855O

All section symbols (§) were replaced with the word "section"
or "sections."
This creates a uniform wording standard across the CMS 855 applications.

Entire 855O

Punctuation, grammar and spelling corrections were made
throughout the CMS 855S as necessary (e.g., upper
case/lower case corrections, apostrophe corrections,
periods inserted in acronyms where necessary, etc.).

Entire 855O

TITLE PAGE

PAGE 1

1. Delete all references to "register" including "registered,"
"registering," "registration," and any other variations of the
word "register" and replace with "enrollment" including
"enrolled," "enrolling," and any other necessary variations of
the word "enroll," including revision of prior or preceding
modifier (e.g., "registering with" revised to "enrolling with").
2. Delete all references to "refer" including "referred,"
"referring," and any other variations of the word "refer" and
replace with "certify" including "certified," "certifying,"
"certification," and any other necessary variations of the
word "certify," including revision of prior or preceding
modifier (e.g., "referring with" revised to "certifying with").
"Registration for Eligible Ordering and Referring Physicians
and Non-Physician Practitioners" was revised to "Enrollment
for Eligible Ordering, Certifying Physicians, and Other
Eligible Professionals"

1. Defined "eligible professionals"
2. Removed interns and fellows the list of physicians and
eligible professionals who may enroll in Medicare solely for
the purpose of ordering and certifying.
3. Defined "licensed residents"
4. Added "retired physicians who are licensed" to the list of
physicians and eligible professionals who may enroll in
Medicare solely for the purpose of ordering and certifying.
5. Changed "...placed on the Medicare Ordering and
Referring Registry..." with "...listed on a CMS database…"

Error correction.

1. Per 42 C.F.R. section 424.502, the definition of “enrollment” now includes the
process that Medicare uses to establish eligibility to order or certify Medicarecovered items and services. For this reason, we must change the previously-used
term “registration” to “enrollment.”
2. Section 424.507(b), uses the term “certify” as opposed to “refer.” “Certify” is the
appropriate term to use when referring to such services. We are therefore utilizing
this term (as opposed to “refer”) throughout this document.

Language updated per 42 C.F.R. section 424.502 and 424.507(b) as stated above.
1. Defined 'eligible professionals" by providing site (42 C.F.R. section 413.75(b)) for
better provider understanding.
2. Interns and fellows are not eligible to enroll in Medicare because they do not have
Medical licenses.
3. Defined licensed residents by providing site (42 C.F.R. section 413.75(b)) for
better provider understanding.
4. Retired physicians added due to their inclusion in section 1848(k)(3)(B) of the
Social Security Act) allowing eligible professionals to order and certify.
5. The Medicare Ordering and Referring Registry will be replaced with a CMS
database as the ordering and referring registry is no longer accurate as it does not
include the new policies and regulations required by new health care law provisions.
The new language of "listed on a CMS database" was supplied by OGC.

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2015 CMS 855O REVISIONS
Section
Number

Change

Reason

SECTION 1

Section 1B - reformatted list and bolded instructions and
removed inters and fellows.
Added checkbox for "Retired physicians who are licensed"

Section 1B - Clarified format and instructions to clarify provider understanding.
Interns and fellows are not eligible to enroll in Medicare because they do not have
Medical licenses.
Retired
physicians added due to their inclusion in section 1848(k)(3)(B) of the Social Security
Act) allowing eligible professionals to order and certify.

SECTION 2

No changes or updates.

n/a

1. Section 3A - simplified "1. If you were, within the last 10
years preceding enrollment/registration, convicted of a
Federal or State felony offense, you must report it in this
section. Reportable offenses include, but are not limited to:
• Felony crimes against persons and other similar crimes for
which the individual was convicted, including guilty pleas and
adjudicated pre-trial diversions;
• Financial crimes, such as extortion, embezzlement, income
tax evasion, insurance fraud and other similar crimes for
which the individual was convicted, including guilty pleas and
adjudicated pre-trial diversions;
• Any felony that placed the Medicare program or its
beneficiaries at immediate risk (such as a malpractice suit
that results in a conviction of criminal neglect or
misconduct); and
• Any felonies that would result in a mandatory exclusion
under Section 1128(a) of the Social Security Act." to "1. Any
federal or state felony convictions (as defined in 42 C.F.R.
section 1001.2) within the preceding 10 years."
2. Section 3B - added "…and/or Medicaid…" after the
words "Medicare" to 5.

1. Section 3A - Language simplification is to align the language with CMS-6045
(“Medicare Program; Requirements for the Medicare Incentive Reward Program and
Provider Enrollment”).
2. Section 3B - CMS can revoke Medicare enrollment under 424.535(a)(12) if the
provider/supplier’s Medicaid billing privileges are terminated or revoked by a State
Medicaid Agency.

SECTION 3

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2015 CMS 855O REVISIONS
Section
Number

SECTION 4

SECTION 5

SECTION 6
SECTION 7
SECTION 8
Medicare
Supplier
Enrollment
Application
Privacy Act
Statement

Change

Reason

1. Section 4A - Revised "Oral Surgery (Dentist only)" into
two categories ("Oral Surgery" and "Dentist").
2. Section 4A - Added new physician specialty
"Interventional Cardiology".
3. Section 4B - Revised title of section from "B. NonPhysician Specialty" to "Eligible Professional or Other NonPhysician Specialty Type".
4. Section 4B - Replaced "...a non-physician practitioner,..."
with "...an eligible professional (as defined in section
1848(k)(3)(B) of the Social Security Act),.." in line 1 of
instructions.
5. Section 4B - replaced "...non-physician practitioner…" with
"...individuals…" in line 2 of instructions.
6. Section 4B - added 5 Specialty Types - "Physical
Therapist", Occupational Therapist", "Qualified Audiologist",
"Qualified Speech-Language Pathologist", and "Registered
Dietician or Nutrition Professional".
Minor text corrections were made to clarify instructions and
delete redundancy.

1. Section 4A - “Oral Surgery (Dentist only)” was split into two categories because
CMS determined that some providers only provide oral surgery services, while other
providers only provide dental services. The differences in physician specialties
relate to provider enrollment requirements.
2. Section 4A - CR 8812 created a new specialty code C3 for Interventional
Cardiology, effective January, 2015.
3. - 5. Section 4B - language updated per 42 C.F.R. section 424.502 and 424.507(b)
and (4.) provided site for "eligible professionals" for provider clarification.
6. Section 4B - Error correction - this creates a uniform specialty type standards
across the applicable CMS 855 applications.

Indicated Section 6 was optional and made minor text
corrections to clarify instructions and delete redundancy.
No changes or updates.
1. Section 8A - replaced # 5 of Certification Statement with
updated language from OGC.
2. Section 8B - removed requirement of signing with blue
ink.

Clarified instructions for better provider understanding.
A portion of providers/suppliers did not want or need a contact person. Allowing it to
be an optional field allows for MAC systems processing without the need for
development of a contact person. Also, clarified instructions for better provider
understanding.
n/a
1. Section 8A - OGC updated certification statement language to include additional
regulation references.
2. Section 8B - requirement was cumbersome and unnecessary for both providers
and Medicare Administrative Contractors.

Corrected website address in paragraph 4.

Error correction.

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