Request for Certification in the Medicare and/or Medicaid Program to Provide Outpatient Physical Therapy (OPT) and/or Speech Pathology Services (OSP)- Initial and Extension Site Requests (CMS-381)
REQUEST FOR CERTIFICATION IN THE MEDICARE AND/OR MEDICAID PROGRAM TO PROVIDE OUTPATIENT PHYSICAL THERAPY (OPT) AND/OR SPEECH PATHOLOGY SERVICES (OSP)- INITIAL AND EXTENSION SITE REQUESTS
Request for Certification in the Medicare and/or Medicaid Program to Provide Outpatient Physical Therapy (OPT) and/or Speech Pathology Services (OSP)- Initial and Extension Site Requests (CMS-381)
Revision of a currently approved collection
No
Regular
Approved without change
07/31/2024
06/12/2024
table that charts list comparision
Inventory as of this Action
Requested
Previously Approved
07/31/2027
36 Months From Approved
07/31/2024
506
0
443
253
0
111
0
0
0
As a result of recent certification process changes (Admin Info 22-02), CMS is revising the Form CMS-381 to streamline the certification processes for initial enrollment of an OPT/OSP. The Form CMS 381 is revised to reflect previous information on the Form CMS 1856 (which will be discontinued) and updated information for Medicare providers of Outpatient Physical Therapy and Speech Pathology Services (OPT) providing services at additional locations in addition to their Medicare approved primary site. These additional locations are called âextension locationsâ and must be reported by the provider and approved by CMS. Form CMS-381 provides a method for OPT providers to meet this reporting requirement. The revised form will be used for initial enrollment and requests for extension locations/sites.
While the burden for this data collection appears to have increased from the previous collection, we note that as a result of this revision, form CMS-1856 will be discontinued for use. The form CMS-1856 was required for all prospective OPT providers to be completed for initial enrollment. Given the information above, 78 new OPT providers would have needed to complete the CMS-1856 form by the equivalent of a Healthcare Support Staff (Healthcare Support Occupations).
The support staff with a mean hourly wage of $16.02 which is $32.04, including fringe benefits, based on the Bureau of Labor Statistics National Occupational Employment and Wage Estimates (https://www.bls.gov/oes/current/oes310000.htm). Therefore, previously had a total annual cost would be $624.78 for all new prospective OPT providers to complete this form upon initial enrollment.
Since CMS has combined content of form CMS-1856 with this new revised form CMS-381 has increased the time for completion by 15 minutes, however has omitted the annual cost of $624.78.
The revised CMS-381 would be at an annual cost of $8,106. If taking the saving of $624.78, the cost would be $3,415.22, which is a minor increase reflective of annual inflation and therefore could be considered a saving.
For the revised CMS-381, we have increased the time burden for this data collection from 111 hours to 253 hours. This is a 142 hour increase in the time burden. We have also increased the cost burden associated with this data collection from $3,116.60 to $8,106. This is as a result of the combined forms.
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-381 REQUEST FOR CERTIFICATION IN THE MEDICARE AND/OR MEDICAID PROGRAM TO PROVIDE OUTPATIENT PHYSICAL THERAPY (OPT) AND/OR SPEECH PATHOLOGY SERVICES (OSP)- INITIAL AND EXTENSION SITE REQUESTS
CMS-381 Supporting Statement for CMS-381 (Clean 2-12-24).docx
Identification of Extension Units of Outpatient Physical Therapy/Outpatient Speech Pathology Providers and Support Regs. (CMS-381)