CMS-855A - Crosswalk Revisions Spreadsheet

Section Number	Revision	Justification
Entire 855A	Punctuation, grammar and spelling corrections were made throughout the CMS-855B as necessary (e.g., upper case/lower case corrections, apostrophe corrections, etc.).	Error corrections.
Entire 855A	Section references were updated to coincide with new section sequencing where necessary.	Formatting corrections.
Entire 855A	Minor text corrections were made to clarify instructions and delete redundancy.	Error corrections.
Entire 855A	All website links and legal references were reviewed and updated where necessary.	Error corrections.
Entire 855A	Removed all references to "Medicare fee-for-service contractor(s)" and replaced language to "Medicare Administrative Contractors (MACs)."	Error correction - updated language.
Entire 855A	Removed all references to "CMS Regional Office" and replaced language to "CMS Location".	Error correction - updated language.
Entire 855A	Removed instruction requiring all signatures to be original and in ink. Faxed, photocopied, or stamped signatures will not be accepted.	Removed because it was an unnecessary requirement causing processing delays for Medicare contractors.
Entire 855A	All acronyms were reviewed and updated where necessary.	Error corrections.
Entire 855A	All section symbols (§) were replaced with the word "section" or "sections".	This creates a uniform standard across the CMS-855 applications.
Entire 855A	All section and subsection headers were made to a standard (numbering, bold, upper and lower case, etc.) to create a uniform format throughout the CMS-855B.	Formatting corrections.
Entire 855A	Reformatted checkboxes for "change," "add," and "remove," with effective date line.	Data fields reformatted to simplify for better provider understanding and creates a uniform wording standard across the CMS-855 applications.
INSTRUCTION PAGES	Added, "Institutional providers must complete this application to enroll in the Medicare program and receive a Medicare billing number."	Added to allow for better provider understanding of how much of the 855A form to complete and reduces MAC development.
INSTRUCTION PAGES	Added, "Be sure you are using the most current version." and the links to where to obtain the current version fo the CMS-855A.	Added to allow for better provider understanding of how much of the 855A form to complete and reduces MAC development.
INSTRUCTION PAGES	Added a note: NOTE: Applicants using this application require a Type 2 NPI. See below for more information.	Notes added for better provider understanding.
INSTRUCTION PAGES	Removed language: "Institutional providers who are enrolled in the Medicare program, but have not submitted the CMS 855A since 2003, are required to submit a Medicare enrollment application (i.e., Internet-based PECOS or the CMS 855A) as an initial application when reporting a change for the first time."	All providers should not be enrolled in PECOS. This language is not needed.
INSTRUCTION PAGES	Added "Opioid Treatment Program" and "Rural Emergency Hospital" to the list of organizations that must complete this application. Added notes: (1) "NOTE: Opioid Treatment Programs may complete the CMS-855A or CMS-855B enrollment application. (2) NOTE: Per Section 125 of the Consolidated Appropriations Act of 2021 (CAA) an action plan is required to be submitted with the enrollment application."	CMS-1715(published in the Federal Register on November 15, 2019 (84 FR 62567)), established a new 42 CFR § 424.67 containing requirements that OTPs must meet and continually adhere to in order to enroll (and remain enrolled) in Medicare effective January 1, 2020. In 2020, Congress established rural emergency hospitals (REHs) as a new provider type. CMS-1772-P incorporates parts of section 1866(kkk)(4) of the Act into 42 CFR Part 424, subpart P.
INSTRUCTION PAGES	Clarified instructions/bullets for completeing and submitting this application.	Added for better provider understanding.
INSTRUCTION PAGES	Changed title of Instructions subsection "Billing Number Information" to "Billing Number and National Provider Identifier Information"	This creates a uniform standard across the CMS-855 applications.
INSTRUCTION PAGES	Added the phrase, "The Provider Transaction Access Number (PTAN), often referred to as a Medicare Provider Number, Medicare Billing Number, CMS Certification Number (CCN), or Medicare “legacy” number, is a generic term for any number other than the National Provider Identifier (NPI) that is used by a providrer to bill the Medicare program.."	Added by MAC request to tell providers that NPIs are not considered Medicare billing numbers which allows better provider understanding and reduces MAC development.
INSTRUCTION PAGES	Added a note explaining the Legal Business Name (LBN) and Tax Identification Number (TIN) the provider furnishes in section 2A must be the same LBN and TIN used to obtain the provider's NPI.	This will allow for better understanding of the requirements for providers and result in less MAC development.
INSTRUCTION PAGES	Added information regarding Type 2 NPI.	Notes added for better provider understanding.
INSTRUCTION PAGES	Added note to "Instructions for Completing and Submitting This Application" subsection stating all information on this form is required with the exception of those fields specifically marked as “optional.”	This will allow for better understanding of the requirements for providers and result in less MAC development.
INSTRUCTION PAGES	Added bullet to "Instructions for Completing and Submitting This Application" subsection, "This form must be typed. It may not be handwritten."	CR 10571 requires applications to be typed.
INSTRUCTION PAGES	Added bullet to "Instructions for Completing and Submitting This Application" subsection, "When necessary to report additional information, copy and complete the applicable section as needed."	This creates a uniform standard across the CMS-855 applications.
INSTRUCTION PAGES	Changed "Avoid Delays in Your Enrollment" to Tips to Avoid Delays in Your Enrollment"	This creates a uniform standard across the CMS-855 applications.
INSTRUCTION PAGES	Added application fee requirement, Electronic Funds Transfer (EFT) Authorization Requirement, and reminders to sign section 15 and include supporting documentation in "Tips To Avoid Delays In Your Enrollment" subsection.	Updated requirements since last application revision.
INSTRUCTION PAGES	Revised subsection for "Additional Information" to include helpful website links, C.F.R. citations and Privacy Act Information regarding the information submitted in this application.	Clarified information for provider understanding and creates uniform wording standard across CMS-855 applications.
INSTRUCTION PAGES	Added a list of acronyms used throughout the CMS-855A.	Clarified information for provider understanding and creates uniform wording standard across CMS-855 applications.
INSTRUCTION PAGES	Added a list of definitions specific to the checkboxes for "add", "change", "remove", "private equity company (for Medicare purposes)", "real estate investment trust (for Medicare purposes)" and "holding company".	Clarified information for provider understanding and creates uniform wording standard across CMS-855 applications. The PI rule (CMS-6084) establishes the ownership disclosure requirements for Part A facilities. The data collection provides greater transparency regarding the owners and managers of Part A facilities, given concerns about the credentials and commitment to high-quality patient care of certain types of nursing home ownership, including private equity firms.
INSTRUCTION PAGES	Changed "Mail Your Application" to "Where to Mail Your Application and revised the mailing instructions.	Clarified information for provider understanding and creates uniform wording standard across CMS-855 applications.
SECTION 1	Deleted subsection "New Enrollees And Enrolled Medicare Providers. "Moved the previous language to the "Who Should Submit This Application" subsection.	Redundant information, removing it reduces provider burden. (This information is included in the subsection "Who Should Complete This Application.")
1	Moved the definitions for "Acquisitions/Mergers", "Consolidation", "Change of Information", and "Revalidation." to the "Who Should Submit This Application" subsection.	Redundant information, removing it reduces provider burden. (This information is included in the subsection "Who Should Complete This Application.")
1A	Removed middle column, "Billing Number Information" with the exception of the "Voluntary Withdrawal" option (where the "Billing Number Information" data field was moved to the first column).	CMS can derive the billing number information from the next section and therefore the collection would be redundant. Deleting this reduces provider burden and creates a uniform standard across the CMS-855 applications. If the provider is voluntarily withdrawing from the Medicare program, the section that identifies the Medicare billing number doesn't apply. Therefore, it was added to the first column for the reason of voluntary withdraw only.
1A	Moved the "You are revalidating your Medicare enrollment" and You are changing your Medicare information" option further up.	This creates a uniform standard across the CMS-855 applications.
1B	Added "What Information is Changing?" and a note to complete certain sections regardless of the change being made.	Added to provide better provider understanding and reduces MAC development.
1B	Expanded choices of "What information is changing?" column.	Expanded choices for ease of completing application, and to minimize provider burden and duplication of information.
1B	Added the "Provider Specific Information." option.	Expanded choices for ease of completing application, and to minimize provider burden and duplication of information.
1B	Added "Business" before Identifying Information.	Expanded choices for ease of completing application, and to minimize provider burden and duplication of information.
1B	Added "Final" before Adverse Legal Actions and removed "Convictions"	This creates a uniform standard across the CMS-855 applications.
1B	Renamed "Practice Location Information, Payment Address & Medical Record Storage Information" to "Address Information" and expanded to capture the different addresses.	Simplified information for provider understanding and creates uniform wording standard across CMS-855 applications.
1B	Added "Opioid Treatment Program Personnel" to "What Information is Changing" section and the applicable sections to complete.	On October 24, 2018, the “SUPPORT for Patients and Communities Act” was signed into law. This legislation was designed to alleviate the nationwide opioid crisis by: (1) reducing the abuse and supply of opioids; (2) helping individuals recover from opioid addiction and supporting the families of these persons; and (3) establishing innovative and long-term solutions to the crisis. Section 2005 of the SUPPORT Act establishes a new Medicare Part B benefit for opioid use disorder (OUD) treatment services furnished by opioid treatment programs (OTPs) beginning on or after January 1, 2020. Implementation of this provision is an important component of the CMS opioid strategy and will help fulfill several of CMS’s strategic goals, including: empowering patients and doctors; ushering state flexibility and local leadership with focus on both treatment and prevention; and supporting innovative approaches to improve quality and accessibility.
1B	Removed subsection "New Enrollee."	Redundant information, removing it reduces provider burden. (This information is included in the subsection "Who Should Complete This Application.")
1B	Under "Special Enrollment Notes", removed "If you are adding an HHA sub-unit (as opposed to a branch), this requires an initial enrollment application for the sub-unit."	HHA subunits have been discontinued.
1B	Under "Special Enrollment Notes", added: "Physician-owned hospital means any participating hospital (as defined in 42 C.F.R. section 489.24) in which a physician, or an immediate family member of a physician has an ownership or investment interest in the hospital. The ownership or investment interest may be through equity, debt, or other means, and includes an interest in an entity that holds an ownership or investment interest in the hospital. This definition does not include a hospital with physician ownership or investment interests that satisfy the requirements at 42 C.F.R. section 411.356(a) or (b)."	Added to clarify the 2A4 question that references the Special Enrollment Notes.
1A and 1B	Updated "Required Sections" column to reflect the application revisions.	Updated information to coincide with the new sections and subsections required by providers, to decrease provider burden, and reduce the collection of duplicative information.
SECTION 2A1	Added "Opioid Treatment Program" and "Rural Emergency Hospital" to the list of organizations that must complete this application.	CMS-1715(published in the Federal Register on November 15, 2019 (84 FR 62567)), established a new 42 CFR § 424.67 containing requirements that OTPs must meet and continually adhere to in order to enroll (and remain enrolled) in Medicare effective January 1, 2020. In 2020, Congress established rural emergency hospitals (REHs) as a new provider type. CMS-1772-P incorporates parts of section 1866(kkk)(4) of the Act into 42 CFR Part 424, subpart P.
2A1	Remove HHA (sub-unit)	Removed the HHA sub-units option as they were eliminated several years ago from being able to enroll.
2A2	Added "Hospital – Transplant Program (Identify organ type(s):"	Added for better clarity. Providers are currently required to check “other” and list the organ types. This option is clearer.
2A3	Removed references to Physician Owned Hospital.	Initially physician owned hospital reporting was no longer required via the CMS-855 applications but was re-added in 2A4 to address OL and CM's concerns and the political implications with the removal of this checkbox.
2A4	Initially removed but re- added "4. Is the provider a physician-owned hospital (as defined in the Special Enrollment Notes on page 8)? -yes -no"	To address OL and CM's concerns and the political implications with the removal of this checkbox.
2B1	Simplified instructions and reordered sections and applicable subsections. Created checkboxes to identify how the individual's business is registered with the IRS (Proprietary, Non-Profit, or Disregarded Entity). Created checkboces to identify government-owned entities and their level. Also added note, "In addition, government-owned entities do not need to provide an IRS Form 501(c)(3)."	These sections and applicable subsections were reformatted to create a more logical flow of information and uniform sequence to the data collected within this section and the PECOS system. The instructions and note were simplified for greater provider understanding and to minimize provider burden and duplication of information. This also creates a uniform standard across the CMS-855 applications.
2B2	Reformatted the "License/Certification/Registration Information" subsection.	This creates a uniform standard across the CMS-855 applications.
2B2	Changed title from "LICENSE/CERTIFICATION INFORMATION" to "LICENSE/CERTIFICATION/REGISTRATION INFORMATION."	Renamed to accurately reflect the data collection and for language to be in sync with other 855 applications.
2B2	Added instructions under title - "Complete the appropriate subsection(s) below for your provider type as you will report in section 2A1. If no subsection is associated with your provider type, check the box stating the information is not applicable."	This note will clarify the instructions for providers to report the certification that is related to their provider type, as applicable.
2B2	Added the word "Active" before "License Information."	This ensures the license being reported is active.
2B2	Added the word "Active" before "Certification Information."	This ensures the certification being reported is active.
2B2	Added a bolded note, "Complete the appropriate subsection(s) below for your provider type as you will report in section 2A1. If no subsection is associated with your provider type, check the box stating the information is not applicable. If you are certified by a national entity, put the word “all” in the “State Where Issued” data field.	This note will clarify the instructions for providers to report the certification that is related to their provider type, as applicable.
2B2	Added data field for "Certifying Entity (Specialty Board, State, Other)" to collect where the certification is coming from.	This information will tell CMS where the certification was obtained to ensure it is legitimate.
2B2	Added note: "Please note: if you are certified by a national entity, put the word "all" in the "State Where Issued" data field."	This clarifies instructions for those providers certified nationally. This will allow providers who have been certified by a national entity to write "all" in the "State Where Issued" data field, showing the certification is national and accepted in all states.
2C	Revised current instruction, "This is the address where correspondence will be sent to the provider listed in section 2B1 by your designated MAC. This address cannot be a billing agent or agency’s address or a medical management company address. If you are reporting a change to your Correspondence Mailing Address, check the box below. This will replace any current Correspondence Mailing Address on file."	The correspondence address is solely used for correspondence between the Medicare Administrative Contractor and the provider.
2C	Added an optional "Attention" field.	Added data field in case provider wants correspondence to be addressed and received by a specific person.
2C	Added "Change" and "Effective Date" fields.	This creates a uniform standard across the CMS-855 applications.
2C	Renamed "Mailing Address" fields to "Correspondence Mailling Address" and PO Box and Apt. # as examples.	This creates a uniform standard across the CMS-855 applications.
2D	Renamed section 2D to Medical Record Correspondence Address. Included instructions "This is the address where the medical record correspondence will be sent to the provider listed in section 2B1 by your designated MAC. This information would be used for any medical record review requests." Data fields also included are a checkbox to use the provider's regular correspondence address, a checkbox to change the Medical Record Correspondence Address, and the address data fields (Attention (optional), 2 Address lines, City/Town, State, Zip Code, Telephone Number, Fax Number, and E-mail Address).	This address was added due to an overwhelming request from the provider/provider community to add a separate field to collect this specific information. MACs requested adding the reason for this address as seen in the first sentence.
2E	Moved existing section 2D Accreditation to 2E Accreditation.	Formatting change to accommodate new section 2D.
2F	Moved existing section 2E Comments to 2F Comments.	Formatting change to accommodate new section 2D.
2G	Moved existing section 2F Change of Ownership (CHOW) Information to 2G Change of Ownership (CHOW) Information.	Formatting change to accommodate new section 2D.
2H	Moved existing section 2G Acquisitions/Mergers to section 2H Acquisitions/Mergers.	Formatting change to accommodate new section 2D.
2I	Moved existing section 2H Consolidations to section 2I Consolidations	Formatting change to accommodate new section 2D.
SECTION 3	Removed references to "Medicare" throughout section.	CMS has Medicare Adverse Legal Action information. Not collecting Medicare information reduces the reporting burden of the provider.
3	Added note to the end of the section description under section title: "To satisfy the reporting requirement, section 3 must be filled out in its entirety, and all applicable attachments must be included."	Clarified information for provider understanding regarding what documents to submit and to help reduce MAC processing denials for "False or Misleading Information" when a provider fails to completely disclose prior adverse actions.
3A	Changed subtitle to read "FEDERAL AND STATE CONVICTIONS (Conviction as defined in 42 C.F.R. Section 1001.2) WITHIN THE PRECEDING 10 YEARS."	Included "(as defined in 42 C.F.R. section 1001.2) within the preceding 10 years" in the title instead of repeating it in numbers 1 through 5 below it. Including the reference in the title simplifies the remaining information and allows for better provider understanding.
3A	Simplified "1. Any federal or state felony conviction(s) by the provider, provider, or any owner or managing employee of the provider or supplier." and added "2. Any crime, under Federal or State law, where an individual or entity has entered into participation in a first offender, deferred adjudication or other program or arrangement where judgment of conviction has been withheld, or the criminal conduct has been expunged or otherwise removed, or there is a post-trial motion or appeal pending, or the court has made a finding of guilt or accepted a plea of guilty or nolo contendere."	Language simplification is to align the language with CMS-6045 (“Medicare Program; Requirements for the Medicare Incentive Reward Program and Provider Enrollment”).
3B	Revised the reporting requirements for exclusions, revocations or suspensions.	Language simplification is to align the language with CMS-6045 (“Medicare Program; Requirements for the Medicare Incentive Reward Program and Provider Enrollment”).
3B	Added "…Medicaid or any federal health care program " to the reporting requirement for revocations or suspensions.	CMS can revoke Medicare enrollment under 424.535(a)(12) if the provider’s Medicaid billing privileges are terminated or revoked by a State Medicaid Agency. Expanded to to include any federal health care program to account for our recently established denial and revocation authorities.
3C	Removed "History" from Final Adverse Legal Action subsection.	This creates a uniform standard across the CMS-855 applications.
3C	Removed "Resolution, if any" column from adverse legal action history table.	CMS has the resolution information. Not collecting adverse legal action resolution information reduces the reporting burden of the provider.
SECTION 4	Expanded and simplified instructions for practice location information.	The instructions were simplified for greater provider understanding and to minimize provider burden and duplication of information. Also creates section standard across CMS-855 applications.
4A	Added data fields for "Medicare Identification Number for this location - CCN (if issued)," "Is this your primary practice locations?" with yes/no checkboxes, "Date you saw your first Medicare patient at this practice location (mm/dd/yyyy)" and data fields for CLIA number and FDA/Radiology Certification Number.	Added for greater provider identification and will result in less MAC development.
4A	Rewrote and reformatted the Hospital and HHA practice location types. Expanded location types to include provider-based locations.	Section 603 of the Bipartisan Budget Act of 2015 (Pub. L. 114–74) ), enacted on November 2, 2015, amended section 1833(t) of the Act and relates to payment for certain items and services furnished by off-campus provider-based departments of a hospital. Requires that we correctly identify off-campus providers and those excepted. New practice location choice added. Reduces provider burden of having to explain this circumstance in section 4D3 (Comments/Special Circumstances).
4A	in hospital only section (2nd and 5th check box in right column)the verbiage "and satisfies applicable requirements at 42 CFR 413.65" was removed.	Deleted verbiage from the applicable checkboxes to avoid confusion and provider concerns.
4B	Added instruction, "Furnish an address where remittance notices and special payments should be sent for services rendered at the practice location(s) reported in section 4A. Please note that payments will be made in your name or, if a business is reported in section 4A, payments will be made in the name of the business."	Note added for provider clarification.
4B	Added checkbox, "Check here if your Remittance Notice/Special Payments should be mailed to your Primary Practice Location Address in Section 4A above and skip this section, OR Check here if your Remittance Notice/Special Payments should be mailed to your Correspondence Address in Section 2C and skip this section."	Added checkbox to reduce possible duplication of reporting for the providers and the other information about the business can be found elsewhere in the application.
4B	Added "Change" and "Effective Date" fields.	This creates a uniform standard across the CMS-855 applications.
4C	Renamed section to "Medicare Beneficiary Medical Records Storage Address"	This creates a uniform standard across the CMS-855 applications.
4C	Added instructions and checkbox, "If all records are stored at the Practice Location reported in section 4A, check the box below and skip this section..."	Added checkbox to reduce possible duplication of reporting for the providers and the other information about the business can be found elsewhere in the application.
4C	Added "Add", "Remove" and "Effective Date" fields.	This creates a uniform standard across the CMS-855 applications.
4C	Add "Name of Storage Facility" under Paper Storage subsection.	Allows CMS to identify where Medicare beneficiary records are stored if needed.
4C	Added electronic storage subsection under "Medicare Beneficiary Medical Records Storage Address."	Some providers no longer store paper beneficiary records. Adding an electronic storage data field option allows CMS to identify where Medicare beneficiary records are stored if needed.
4C2	Revised verbiage to: “If yes, identify the service used to store these records below. This can be an in-house software program, online service, vendor, etc.” and field below to read “Service used to store electronic records”	Changed language from “If yes, identify the service used to store where/how these records are stored below. This can be a website, URL, in-house software program, online service, vendor, etc. This must be an electronic storage site to which CMS or its designees can be provided access if necessary.” to “If yes, identify the service used to store these records below. This can be an in-house software program, online service, vendor, etc.” in response to a commenters concern of verbiage related to electronic medical record storage. Field below titled “Site where electronic records are stored” changed to “Service used to store electronic records”
4D	Added "NOTE: When necessary to report more than one base of operations, copy and complete this section for each base of operations."	Clarified information for provider understanding regarding what is requried to be included in this section.
4D	Added "Change", "Add", "Remove" and "Effective Date" fields.	This creates a uniform standard across the CMS-855 applications.
4D	Added checkbox, "The “Base of Operations” is the same as the “Practice Location” reported in Section 4A."	Added checkbox to reduce possible duplication of reporting for the providers and the other information about the business can be found elsewhere in the application.
4D	Added "Base of Operation" before Street Address information.	This creates a uniform standard across the CMS-855 applications.
4E	Added note "For each vehicle, submit a copy of all health care related permits/licenses/registrations" and remove checkbox for vehicle information.	This creates a uniform standard across the CMS-855 applications.
4E	Removed the option for the provider to change vehicle information, leaving only the options to add or remove vehicle information.	Adding and removing vehicle information is actually changing the information. CMS found the change option to be misleading and confusing to the provider so CMS simplified the information for better provider understanding.
4F	Added "/Territory" next to State column so it reads "State/Territory" throughout the section.	Added if "State" was not applicable and will be a section standard across CMS-855 applications.
4F1	Added column for "County" in table showing where the providers render mobile services .	Added if "City/Town" was not applicable and creates section standard across CMS-855 applications.
4F2	Added column for "County" in table showing where the providers render mobile services .	Added if "City/Town" was not applicable and creates section standard across CMS-855 applications.
SECTION 5	Clarified instructions on who needs to be reported in this section.	This will allow for better understanding of the requirements for providers and results in less MAC development.
5	Added "NOTE: It is not necessary for the organization reported in 2A1 to report itself in this section."	Added by MAC request, an entity cannot own itself, if the entity completes this section, it is duplicate information. This note reduces provider burden and MAC processing.
5	Included note in instructions: "The provider must submit an organizational structure diagram/flowchart identifying all the entities listed in section 5 and their relationships with the provider and each other."	This will allow for better understanding of the requirements for providers and results in less MAC development.
5	Added "Private equity company" and "Real estate investment trusts" in 5. Additional Information on Ownership.	The PI rule (CMS-6084) establishes the ownership disclosure requirements for Part A facilities. The data collection provides greater transparency regarding the owners and managers of Part A facilities, given concerns about the credentials and commitment to high-quality patient care of certain types of nursing home ownership, including private equity firms.
5A	Renamed 5A to Organization with Ownership Interest and/or Managing Control - Identification Information	This creates a uniform standard across the CMS-855 applications.
5A	Added language "If you are changing, adding or removing information about your current ownership interest and/or managing control information for this organization, check the applicable box, furnish the effective date, and complete the appropriate fields in this section." Added checkboxes adn effective date field.	This creates a uniform standard across the CMS-855 applications.
5A	Added telephone number, fax number and email address fields to the section.	Added at the request of DOJ, to collect contact information of owners to notify them of changes made to the enrollment information.
5A	Added instructions under identifying information section - "Identify the type of ownership and/or managing control the individual identified above has in the provider identified in Section 2B1 of this application. Check all that apply. Complete all information for each type of ownership and/or managing control applicable, including the exact percentage of ownership. Combined percentage totals for direct owners should not exceed one hundred percent."	This will clarify what information needs to be reported in this section.
5A	Reformatted the ownership/managing control tables and the percentage of ownership.	Added for greater provider identification and will result in less MAC development.
5A	Added the question "Is this organization itself owned by any other organization or by any individual? Yes No" to all the ownership roles.	Added at the request of HHS/ASPE to identify organizations, such as SNFs or hospitals, with the same ultimate parent. This would facilitate investigating whether a program integrity issue found in one provider was prevalent in other providers under the same ultimate parent, further expanding CPI’s ability to investigate patterns of program integrity issues.
5A	Incorporated the previous Chain Home Office section (section 7) into Section 5.	Reformatted the section to incorporate chain home office information as an ownership or managing control type. No new data elements are being captured.
5B	Revised instructions to capture information about the structure of the organization reported in the previous section (IRS business designation, business structure, type of organization). Included definitions for "Private equity company (for Medicare purposes)", "Real estate investment trust (for Medicare purposes)", and "Holding company".	The PI rule (CMS-6084) establishes the ownership disclosure requirements for Part A facilities. The data collection provides greater transparency regarding the owners and managers of Part A facilities, given concerns about the credentials and commitment to high-quality patient care of certain types of nursing home ownership, including private equity firms.
5C	Moved the Chain Home office information from section 7 to section 5C. Added change, remove checkboces and effective date field. Removed the effective date column in the table.	Reformatted the section to incorporate chain home office information as an ownership or managing control type. No new data elements are being captured.
5D	Renamed subsection to "Final Adverse Legal Action".	This creates a uniform standard across the CMS-855 applications.
5D	Added instruction under final adverse legal action, "Complete this section for the organization reported in section 5A above. If you need additional information regarding what to report, please refer to section 3 of this application. All supporting documentation must be included as described in section 3."	Gave a reference for greater provider understanding.
5D	Added: "NOTE: If reporting more than one organization, copy and complete sections 5A and 5B for each organization reported."	Note added for provider clarification and will allow for less MAC development.
5D	Added: "NOTE: To satisfy the reporting requirement, section 5D must be filled out in its entirety, and all applicable attachments must be included."	Note added for provider clarification and will allow for less MAC development.
5D	Removed "Resolution, if any" column from adverse legal action history table.	CMS has the resolution information. Not collecting adverse legal action resolution information reduces the reporting burden of the provider.
SECTION 6A	Added "limited" to the following sentence "All general and limited partnership interests, regardless of the percentage. This includes: (1) all interests in a non- limited partnership, and (2) all general and limited partnership interests in a limited partnershipanguage that partnership interest includes general and limited."	Added for provider clarification.
6A	Added "medical director" to the list of managing employee examples.	Added for provider clarification.
6A	Revised the instructions to "If you are changing, adding, or removing information about your current ownership interest and/or managing control information for this individual, check the applicable box, furnish the effective date, and complete the appropriate fields in this section."	This creates a uniform standard across the CMS-855 applications.
6A	Added "Change", Add", "Remove" and "Effective Date" fields.	This creates a uniform standard across the CMS-855 applications.
6A	Deleted data fields: Place of Birth, Country of Birth, Medicare Identification Number (if issued) and NPI (if issued).	CMS no longer collects location birth data and CMS can discern identification numbers and NPI (if issued) elsewhere on the application therefore decreasing provider burden.
6A	Added data field: Title.	This creates a uniform standard across the CMS-855 applications.
6A	Added ITIN to Social Security Number data field so it now reads, "Social Security Number (SSN) or Individual Tax Identification Number (ITIN)"	Updated data collection to include ITINs to include providers with special circumstances.
6A	Added telephone number, fax number and email address fields to the section.	Added at the request of DOJ, to collect contact information of owners to notify them of changes made to the enrollment information.
6A	Added instructions under identifying information section to "Identify the type of ownership and/or managing control the individual identified above has in the provider identified in Section 2B1 of this application. Check all that apply. Complete all information for each type of ownership and/or managing control applicable, including the exact percentage of ownership. Combined percentage totals for direct owners should not exceed one hundred percent."	This will clarify what information needs to be reported in this section.
6A	Reformatted the ownership/managing control tables and the percentage of ownership.	Added for greater provider identification and will result in less MAC development.
6B	Renamed subsection to "Final Adverse Legal Action".	This creates a uniform standard across the CMS-855 applications.
6B	Added instruction under final adverse legal action, "Complete this section for the organization reported in section 5A above. If you need additional information regarding what to report, please refer to section 3 of this application. All supporting documentation must be included as described in section 3."	Gave a reference for greater provider understanding.
6B	Added: "NOTE: If reporting more than one individual, copy and complete sections 6A and 6B for each individual reported."	Note added for provider clarification and will allow for less MAC development.
6B	Added: "To satisfy the reporting requirement, section 6B must be filled out in its entirety, and all applicable attachments must be included."	Note added for provider clarification and will allow for less MAC development.
6B	Removed "Resolution, if any" column from adverse legal action history table.	CMS has the resolution information. Not collecting adverse legal action resolution information reduces the reporting burden of the provider.
SECTION 7	Moved Chain Home Office Information to section 5.	Chain home office information has been consolidated with section 5.
SECTION 8	Added "/Agent" after the word "Agency" to include individuals in the instructions.	Error correction - individual agents were included in the data fields, but not in the instructions for the section.
8	Added "NOTE: The billing agency/agent address cannot be the correspondence mailing address completed in section 2C of this application."	Note added for provider clarification.
8	Added "If you are changing information about your current billing agency/agent or adding or removing billing agency/agent information, check the applicable box, furnish the effective date, and complete the appropriate fields in this section."	Added for provider clarification.
8	Added "Change", "Add", "Remove" and "Effective Date" fields.	This creates a uniform standard across the CMS-855 applications.
8	Replaced "Individual Billing Agent" with "If Billing Agent".	Note added for provider clarification.
SECTION 10	Replaced "For Future Use (This Section Not Applicable)" with "Opioid Treatment Program Personnel".	Added to be in compliance with the SUPPORT Act of 2018.
10	Added instructions to capture information for individuals legally authorized to order and/or dispense controlled substances at OTP facility	Added to be in compliance with the SUPPORT Act of 2018.
10A	Added subsection "Ordering Personnel Identification" to capture ordering personnel information.	Added to be in compliance with the SUPPORT Act of 2018.
10B	Added subsection "Dispensing Personnel Identfication" to capture dispensing personnel information.	Added to be in compliance with the SUPPORT Act of 2018.
SECTION 12	In the instructions, removed the references to HHA sub units in the instructions and updated instructions for HHA initial reserve operating funds.	On January 13, 2017, CMS published a final rule revising the Conditions of Participation (CoPs) for HHAs which was scheduled to become effective on July 13, 2017. A subsequent rule delayed the implementation of these CoPs until January 13, 2018. The final rule eliminated the definition for “subunit,” previously set forth at §484.2.
12B	Adding language, "If you are changing information about your current nursing registries or adding or removing nursing registries information, check the applicable box, furnish the effective date, and complete the appropriate fields in this section."	Added for provider clarification.
12B	Added checkboxes for "change", "add", and "remove", with effective date.	Data field added to sync to the PECOS system.
SECTION 13	Made section optional.	Section was made optional to reduce the reporting burden on the provider and because it was an unnecessary requirement causing processing delays for Medicare contractors.
13	Added "Contact Person" before Address Line 1 and Address Line 2 fields.	This creates a uniform standard across the CMS-855 applications.
13	Added "NOTE: The Contact Person listed in this section will only be authorized to discuss issues concerning this or any other enrollment application. Your designated MAC will not discuss any other Medicare issues about you with the above Contact Person."	Added information for greater provider understanding about what role the contact person has.
SECTION 14 #3	Replaced current number 3 with updated language and references concerning the Civil False Claims Act.	The Department of Justice requested this language to be updated from the older summary language. OGC confirmed the revised language. Language has been/will be updated across all CMS-855 applications.
SECTION 15	Revised the language regarding authorized official signatures, "Only an authorized official has the authority to sign (1) the initial enrollment application on behalf of the provider and (2) add or remove additional authorized officials and delegated officials. Once the delegation of authority has been established all other enrollment application submissions can be signed by either an authorized official or delegated official."	Added for greater provider identification and will result in less MAC development.
15	Added in bold "EACH AUTHORIZED AND DELEGATED OFFICIAL MUST HAVE AND DISCLOSE HIS/HER SOCIAL SECURITY NUMBER."	Added note for clarity that an SSN is required to be disclosed.
15	Replaced paragraph 6 of instructions from "Only an authorized official has the authority to sign (1) the initial enrollment application on behalf of the provider or (2) the enrollment application that must be submitted as part of the periodic revalidation process. A delegated official does not have this authority." to "Only an authorized official has the authority to sign (1) the initial enrollment application on behalf of the provider and (2) add or remove additional authorized officials and delegated officials. Once the delegation of authority has been established all other enrollment application submissions can be signed by either an authorized official or delegated official."	Updated instructions to better clarify distinct roles of providers for better provider understanding.
15A #1	Added, "I authorize the Medicare contractor to verify the information contained herein."	OGC updated certification statement language to include additional regulation references.
15A #2	Removed "deliberate" from #2.	At the request of OGC. AUSA has advised their inability to prosecute, in some cases, because they were unable to prove ‘deliberate’ in context of false or misleading information.
15A #3	Replaced #3 of the certification statement with updated language from OGC.	OGC updated certification statement language to include additional regulation references.
15A #4	Added "five percent or greater" and removed "physician owner or investor or any other"	This clarifies the requirements that the provider must meet and maintain in order to bill the Medicare program.
15B	Renamed section to "Authorized Official Signature(s)"	This creates a uniform standard across the CMS-855 applications.
15B1/15B2	Added "Add", "Remove" and "Effective Date" fields.	Data fields reformatted to simplify for better provider understanding and creates a uniform wording standard across the CMS-855 applications.
15B1/15B2	Added, "In order to process this application it MUST be signed and dated."	This creates a uniform standard across the CMS-855 applications.
15C	Combined sections 15 and 16 and updated headers and numbering.	CMS-855A ends at Section 15 (Certification Statement and Signature) and creates section standard across CMS-855 applications.
15C	Renamed to "Additional Requirements for Medicare Enrollment for Delegated Officials"	This creates a uniform standard across the CMS-855 applications.
15C	Added "NOTE: Delegated Officials are optional.	Creates section standard across CMS-855 applications.
15D	Moved Delegated Officials (optional) signatures from section 16.	CMS-855B ends at Section 15 (Certification Statement and Signature) and creates section standard across CMS-855 applications.
15D	Added "Add", "Remove" and "Effective Date" fields.	Data fields reformatted to simplify for better provider understanding and creates a uniform wording standard across the CMS-855 applications.
15D	Added, "In order to process this application it MUST be signed and dated."	This creates a uniform standard across the CMS-855 applications.
15B	Removed instruction, "All applications must be original and signed in blue ink. Applications with signatures deemed not original or not dated will not be processed. Stamped, faxed, or copied signatures will not be accepted." Replaced with instruction, "In order to process this application, it must be signed and dated."	Removed because the color of ink was an unnecessary requirement causing processing delays for Medicare contractors. In addition, information technology has allowed many new submission avenues for providers to submit this application.
SECTION 16	Deleted section 16 and combined sections 15 and 16.	CMS-855B ends at Section 15 (Certification Statement and Signature) and creates section standard across CMS-855 applications.
15D	Relocated OMB Statement from end of section 17 to end of section 15.	CMS-855B ends at Section 15 (Certification Statement and Signature) and creates section standard across CMS-855 applications.
SECTION 17	Renamed title to "Supporting Documentation Information"	This creates a uniform standard across the CMS-855 applications.
17	Combined the first two paragrahps of the instructions.	This creates a uniform standard across the CMS-855 applications.
17	Removed the "Mandatory for all Provider/Supplier Types", "Mandatory for Selected Provider/Supplier Types", and Mandatory, If Applicable" headings and consolidated the list if supporting documentation.	This creates a uniform standard across the CMS-855 applications.
17	Added "Territory" to "Federal, State, and/or local (city/county) business licenses, certifications and/or registrations required to operate a health care facility".	This creates a uniform standard across the CMS-855 applications.
17	Revised to, "Copy(s) of all bills of sale or sales agreements for all ownership changes. This includes, CHOWS, Acquisition/Mergers, and Consolidations, and all other ownership changes that are required to be reported, regardless of the percentage involved (e.g., new 15 percent owner).	This creates a uniform standard across the CMS-855 applications.
17	Added "final" to "Copy(s) of all adverse legal action documentation (e.g., notifications, resolutions, and reinstatement letters)."	This creates a uniform standard across the CMS-855 applications.
17	Added "(e.g., IRS Form 501(c)(3))." to "Copy of IRS Determination Letter, if provider is registered with the IRS as non-profit."	This creates a uniform standard across the CMS-855 applications.
17	Added "Organizational structure diagram/flowchart identifying all of the entities listed in section 5 and their relationships with the provider and each other, Copy of all mobile vehicle registrations (all mobile services) and Rural Emergency Hospital (REH) Action Plan to the list of supporting documentation.	This creates a uniform standard across the CMS-855 applications.
PRIVACY ACT STATEMENT (Last page)	Updated Privacy Act Statement.	Error correction.