CMS-855B - Supporting Statement - 30-day

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Medicare Enrollment Application for Clinics/Group Practices and Other Suppliers (CMS-855B)

OMB: 0938-1377

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Supporting Statement for Paperwork Reduction Act Submissions

Medicare Enrollment Application for Clinics/Group Practices and Other Suppliers Form CMS-855B (OMB Control Number: 0938-1377) Revision and Reinstatement of Currently Approved Collection



BACKGROUND


The primary function of the Form CMS-855B Medicare enrollment application is to gather information from an organizational supplier that tells us who it is, whether it meets certain qualifications to be a health care supplier, where it practices or renders services, the identity of its owners, and other information necessary to establish correct claims payments.


This information collection request (ICR) seeks:

  • Approval for revisions to the Form CMS-855B. In general, these changes will gather certain additional data to help: (1) Medicare Administrative Contractors (MAC) validate the accuracy and completeness of the information the supplier furnishes; and (2) ensure that payments are made only to qualified and legitimate organizational suppliers.

  • To reinstate the Form CMS-855B, the OMB approval date for which expired on March 31, 2024.


  1. JUSTIFICATION


  1. Need and Legal Basis


Various sections of the Act, the United States Code (U.S.C.), Internal Revenue Service (IRS) Code, and the CFR require providers and suppliers to furnish information concerning the amounts due and the identification of individuals or entities that furnish medical services to beneficiaries before payment can be made.


  • Sections 1814(a), 1815(a), and 1833(e) of the Act require the submission of information necessary to determine the amounts due to a provider or other person.

  • Section 1842(r) of the Act requires us to establish a system for furnishing a unique identifier for each physician who furnishes services for which payment may be made. To do so, we need to collect information unique to that provider or supplier.

  • The Balanced Budget Act of 1997 (BBA) (Public Law 105-33), section 4313, amended sections 1124(a)(1) and 1124A of the Act to require disclosure of both the employer identification number (EIN) and social security number (SSN) of each provider or supplier, each person with ownership or control interest in the provider or supplier, and any managing employees.

  • Section 31001(I) of the Debt Collection Improvement Act of 1996 (DCIA) (Public Law 104-134) amended 31 U.S.C. 7701 by adding paragraph (c) to require that any person or entity doing business with the federal government provide their tax identification number (TIN).

  • Sections 1866(b)(2)(D) and 1842(h)(8) of the Act require denial of enrollment (directly or indirectly) of persons convicted of a felony for a period not less than 10 years from the date of conviction.

  • The IRS Code, section 3402(t), requires us to collect additional information about the proprietary/non-profit structure of a Medicare provider/supplier to allow exclusion of non-profit organizations from the mandatory 3% tax withholding.

  • IRS section 501(c) requires each Medicare provider/supplier to report information about its proprietary/non-profit structure to the IRS for tax withholding determination.

  • Section 6401 of the Affordable Care Act (which amended section 1866(j) of the Social Security Act) outlines requirements for the enrollment of providers and suppliers into the Medicare program.

  • We are authorized to collect information on the Form CMS-855B (Office of Management and Budget (OMB) approval number 0938-1377) to ensure that correct payments are made to suppliers under the Medicare program as established by Title XVIII of the Act.


The Form CMS-855B application captures the foregoing information, including the data required to uniquely identify and enumerate the supplier. Additional information needed to process claims accurately and timely is also collected on the application.


  1. Purpose and Users of the Information


The Form CMS-855B application is submitted when the applicant first requests Medicare enrollment. The application is used by the MACs to collect data to ensure the applicant has the necessary credentials to provide the health care services for which they intend to bill Medicare; this includes data that allows the Medicare contractor to correctly price, process, and pay the applicant’s claims. It also gathers information that enables MACs to ensure that the supplier is neither excluded from the Medicare program nor debarred, suspended, or excluded from any other federal agency or program. The application is also used by enrolled suppliers when they are reporting a change in their ownership, a change in their current Medicare enrollment information, or are revalidating or reactivating their Medicare enrollment.


  1. Improved Information Techniques


This collection lends itself to electronic collection methods. The Provider Enrollment, Chain and Ownership System (PECOS) is a secure, intelligent, and interactive national data storage system maintained and housed within the CMS Data Center with limited user access through strict CMS systems access protocols.  Access to the data maintained in PECOS is limited to CMS and Medicare contractor employees responsible for supplier enrollment activities.  The data stored in PECOS mirrors the data collected on the Form CMS-855 (Medicare Enrollment Applications) and is maintained indefinitely as both historical and current information.  CMS also supports an internet-based supplier Form CMS-855 enrollment platform, which allows the supplier to complete an online Form CMS-855 enrollment application and transmit it to the Medicare contractor database for processing; the data is then transferred from the Medicare contractor processing database into PECOS by the MAC. Periodically, CMS will require adjustment to the format of the Form CMS-855 (either paper, electronic or both) for clarity or to improve form design.  These adjustments do not alter the current OMB data collection approval.


  1. Duplication and Similar Information


There is no duplicative information collection instrument or process.


  1. Small Business


The data collections associated with the Form CMS-855 application process impacts small businesses. However, because of the relative infrequency with which the information needs to be submitted, we believe the overall impact on small businesses is negligible.


  1. Less Frequent Collections


This information is collected on an as needed basis. The information provided on the Form CMS-855 is required for enrollment in the Medicare program. It is essential to collect this data the first time a supplier enrolls with a Medicare contractor so that CMS’ contractors can ensure that the supplier meets all statutory and regulatory requirements necessary for enrollment and that claims are paid correctly.


In addition, to ensure uniform data submissions, CMS requires that all changes to previously submitted enrollment data be reported via the appropriate provider enrollment application.


  1. Special Circumstances


There are no special circumstances that will require an information collection to be conducted in a manner that requires respondents to:


  • Submit more than an original and two copies of any document.

  • Retain records -- other than health, medical, government contract, grant-in-aid, or tax records -- for more than three years.

  • Collect data in connection with a statistical survey that is not designed to produce valid and reliable results that can be generalized to the universe of study.

  • Use a statistical data classification that has not been reviewed and approved by OMB.

  • Include a pledge of confidentiality that: (1) is not supported by authority established in statute or regulation; (2) is not supported by disclosure and data security policies consistent with that pledge; and/or (3) unnecessarily impedes the sharing of data with other agencies for compatible confidential use.

  • Submit proprietary trade secret or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.


  1. Federal Register Notice/Outside Consultation


No rulemaking is associated with our requested Form CMS-855B revisions.


The 60-day notice for this information collect request was published in the Federal Register on July 9, 2024 (89 FR 56382). A 30-day Notice published on January 15, 2025. No public comments were submitted.


  1. Payment/Gift to Respondents


No payments or gifts are being provided to respondents.


  1. Confidentiality


Except as explained in Section 16 of this Supporting Statement: (1) all information collected will be kept private in accordance with 5 U.S.C. 552(b)(4), Executive Order 12600, and 45 CFR 155.260 (Privacy and Security of Personally Identifiable Information); and (2) privileged or confidential commercial or financial information is protected from public disclosure by federal law.


  1. Sensitive Questions


There are no sensitive questions associated with this collection. Specifically, the collection does not solicit questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.


  1. Burden Estimate of Requested Form CMS-855B Changes


a. Introduction


This section 12 outlines our requested Form CMS-855B revisions that we believe will involve: (1) a change in burden for suppliers that complete this application; or (2) an explanation of why no burden change is involved. (Other application revisions not involving a burden change or requiring additional explanation are listed in the “Summary of Form CMS-855B Changes” Excel spreadsheet.)


We will use the following median wage category and hourly rate from the U.S. Bureau of Labor Statistics’ (BLS) May 2024 National Occupational Employment and Wage Estimates for all salary estimates (http://www.bls.gov/oes/current/oes_nat.htm):


TABLE 1: NATIONAL OCCUPATIONAL EMPLOYMENT AND WAGE ESTIMATES


Occupation Title

Occupation Code

Median Hourly Wage ($/hr)

Fringe Benefits and Overhead ($/hr)

Adjusted Hourly Wage ($/hr)

Office and Administrative Support Workers, All Other

43-9199

20.78

20.78


41.56

Healthcare Diagnosing or Treating Practitioners, All Other


29-1290

51.92

51.92

103.84

Physicians, All Other

29-1229

113.46

113.46

226.92



These wage categories reflect the following:


  • The Form CMS-855B (including the new data/revised elements) will be completed by office/administrative staff and reviewed/signed by a practitioner within the supplier entity.

  • The reassigning individual, typically a physician, will sign the certification statement in Section 15.


Along with these wage estimates, the burden below is based on the anticipated number of Form CMS-855B application receipts, which in turn is based on PECOS data. For purposes of this information collection request (ICR), there are several categories of Form CMS-855B transactions:


  • Initial enrollment

  • Enrolling with another MAC

  • Revalidation

  • Reactivation

  • Reporting a change of information

  • Voluntarily withdrawing from Medicare


Tables 2 and 3 break down the baseline per application hour and cost burdens. Our approach will mirror that utilized in previous Form CMS-855B supporting statements – specifically, office staff will complete the application while a physician or practitioner reviews and signs it. For purposes of this ICR, and as indicated above, we will use the physician rate when the individual must sign the application because he/she is reassigning his/her benefits to the organizational supplier. The practitioner rate will be applied in all other cases.


(Note that we do not anticipate any burden changes to the “Voluntarily Withdrawing from Medicare” category. This is because voluntarily withdrawing suppliers only complete a few data elements on the Form CMS-855B, none of which include the new/revised elements addressed in this Section 12. We thus will not include them in any tables in Section 12 or 15.)



TABLE 2 – PROJECTED BASE BURDEN/COST PER APPLICATION – HEALTH

DIAGNOSING & TREATING PRACTITIONER SIGNATURE


Reason for Submittal

Time for Completion by Administrative Staff (hours)

Time for a Health Diagnosing and Treating Practitioner to Review and Sign (hours)

Total Time for Completion Per Response (hours)*

Cost for Completion by Administrative Staff ($)

Cost for Review and Signature by a Health Diagnosing and Treating Practitioner ($)

Total Cost of Completion (per Response) *


Initial

Enrollment

2.5

0.5

3

103.90 (2.5 x 41.56)

51.92 (0.5 x 103.84)

155.82

Enrolling

with Another MAC


1.5


0.5


2

62.34 (1.5 x 41.56)

51.92 (0.5 x 103.84)

114.26

Revalidation

1.5

0.5

2

62.34 (1.5 x 41.56)

51.92 (0.5 x 103.84)

114.26

Reactivation

1.5

0.5

2

62.34 (1.5 x 41.56)

51.92 (0.5 x 103.84)

114.26

Reporting a Change of Medicare Enrollment

Information



0.75



0.25



1



31.17 (0.75 x 41.56)



25.96 (0.25 x 103.84)



57.13


TABLE 3 – PROJECTED BASE BURDEN/COST PER APPLICATION RESPONSE –

PHYSICIAN SIGNATURE


Reason for Submittal

Time for Completion by Administrative Staff (hours)

Time for a Physician to Review and Sign (hours)

Total Time for Completion Per Response (hours)*

Cost for Completion by Administrative Staff ($)

Cost for Review and Signature by a Physician ($)

Total Cost of Completion (per Response) *


Initial

Enrollment

2.5

0.5

3

103.90 (2.5 x 41.56)

113.46 (0.5 x 226.92)

217.36

Enrolling

with Another MAC


1.5


0.5


2

62.34 (1.5 x 41.56)

113.46 (0.5 x 226.92)

175.80

Revalidation

1.5

0.5

2

62.34 (1.5 x 41.56)

113.46 (0.5 x 226.92)

175.80

Reactivation

1.5

0.5

2

62.34 (1.5 x 41.56)

113.46 (0.5 x 226.92)

175.80

Reporting a Change of Medicare Enrollment

Information



0.75



0.25



1



31.17 (0.75 x 41.56)



56.73 (0.25 x 226.92)



87.90



b. Revisions to Current Figures


In our most recent Form CMS-855B ICR, we outlined the following number of Form CMS-855B submissions we receive on average each year for the five above-mentioned categories. The sixth approved category involves home infusion therapy (HIT) supplier enrollment. Burdens are included.

TABLE 4 – MOST RECENT FORM CMS-855B AVERAGE ANNUAL RECEIPT

TOTALS


Reason for Submittal

Total Number of

Respondents

Total Number of Responses

Time per Response (hours)

Total Annual Time (hours)

Total Annual Cost ($)

Initial Enrollment

15,797

15,797

3

47,391

2,283,301

Enrolling with Another MAC

37

37

2

74

3,953

Revalidation

31,211

31,211

2

62,422

3,334,271

Reactivation

1,316

1,316

2

2,632

140,588

Reporting a Change of Information

55,650

55,650

1

55,650

2,972,823

HIT Supplier Enrollment

700

700

2.5

1,750

106,744

Total

104,711

104,711

Varies

169,919

8,841,680


We are in this ICR updating these categories and totals as follows:


(i) HIT Suppliers


  • The respondent/response, total annual time, and total annual cost figures for HIT suppliers in Table 4 are the combined totals over 3 years rather than the annual amounts (e.g., 700/3). These figures should instead be, respectively, 233 respondents/responses, 583 annual hours, and $35,581.

  • Since these HIT supplier enrollments were effectively initial enrollments, we believe a 3-hour per response figure, instead of 2.5 hours, is more appropriate.

  • For this same reason, we will merge the HIT Supplier Enrollment category (with the above-mentioned modified annual figures) into the Initial Enrollment category. The HIT Supplier Enrollment category will be eliminated.


This revises Table 4’s categories and totals as follows:


TABLE 5 –FORM CMS-855B ANNUAL BURDEN FIGURES WITH HIT

SUPPLIER CATEGORY MERGED INTO INITIAL ENROLLMENTS


Reason for Submittal

Total Number of

Respondents

Total Number of Responses

Time per Response (hours)

Total Annual Time (hours)

Total Annual Cost ($)

Initial Enrollment

16,030

16,030

3

47,974

2,318,882

Enrolling with Another MAC

37

37

2

74

3,953

Revalidation

31,211

31,211

2

62,422

3,334,271

Reactivation

1,316

1,316

2

2,632

140,588

Reporting a Change of Information

55,650

55,650

1

55,650

2,972,823

Total

104,244

104,244

Varies

168,752

8,770,517


(ii) Updated Annual Totals


Based on new PECOS data, we believe the actual number of several categories of annual application receipts is higher than that shown in Tables 4/5. We are therefore revising them for accuracy in Table 6 as part of this ICR. We will use these updated totals as the baseline for our requested revised estimates.


TABLE 6 – FORM CMS-855B REVISED CURRENT BURDEN FIGURES

BASED ON PECOS DATA


Reason for Submittal

Number of

Respondents

Total Number of Responses *

Time per Response (hours)

Total Annual Time (hours)

Total Annual Cost ($) **

Initial Enrollment

42,083 *

42,083 *

3

126,249 *

6,557,794 *

Enrolling with Another MAC

37

37

2

74

4,228

Revalidation

41,608

41,608

2

83,216

4,754,130

Reactivation

5,761

5,761

2

11,522

658,252

Reporting a Change of Information

78,489

78,489

1

78,489

4,484,077

Total

167,978

167,978

Varies

299,550

16,458,481


* Includes all HIT supplier applications.

** Applies the Table 2 (Practitioner) wage estimates for each application category (e.g., for initial applications, $155.82 x 42,083; for revalidations, $114.26 x 41,608; etc.)


c. New/Revised Data Elements


Most of the changes addressed below are to isolated sections of the Form CMS-855B. Except as otherwise indicated, the burden will only pertain to the specific section of the application that is being revised. For such situations involving initial, revalidation, and reactivation submissions (as well as those involving enrollment with another MAC), we will use the above-referenced $41.56 wage for administrative staff alone rather than the higher, combined administrative staff/practitioner total (e.g., $114.26 for reactivations). This is because the signature burden for practitioners is already included in the current OMB-approved burden; the only changed burden will, again, involve the revised section of the application that administrative staff will complete. To illustrate, suppose a supplier is submitting a Form CMS-855B revalidation application. As part of this, it must complete a new data element in Section 4. The new burden will only involve administrative staff’s furnishing of this information; the practitioner will not have additional burden, for he or she will still sign the application regardless of whether the new data element was added to the form.


Unless noted otherwise, the change of information (COI) category will use the combined administrative staff/practitioner figure of $57.13 because: (1) the COI will involve a change to the new/revised data; and (2) this will constitute a new COI submission and, hence, require a practitioner signature.


(i) Section 1(A) (Reason for Submitting This Application)


Enrolling and enrolled suppliers must check the applicable box in Section 1A to identify the reason it is submitting the application. We are adding a new submittal reason: “You are solely enrolling in Medicare to participate in Medicaid or another health care program and will not bill Medicare.” This will not implicate any new burden. It is merely another option via which the supplier can identify its submittal reason.


(ii) Section 1(A) (Reason for Submitting This Application)


For the voluntary termination submittal reason/checkbox, we are adding Sections 2A3 and 4B as optional sections that the supplier may complete. As the supplier is not required to complete them, there is no burden associated with this change.


(iii) Section 2(A)(1) (Supplier Identification Information – Business Information)


In the business structure portion of Section 2(A)(1) in which the supplier identifies its organizational type, we are adding checkboxes for "sole owner", “general partnership”, “limited partnership”, and government-owned supplier. These checkboxes are merely additional options via which the supplier can identify its business type and will involve no burden change.


(iv) Section 2(B)(1) (Type of Supplier)


In Section 2(B)(1), the supplier checks which type of supplier it is. We are adding the following new checkboxes to this section: “home infusion therapy”; “physical therapy group in private practice”; and “occupational therapy group in private practice”. This will not impose any new burden, for the additional checkboxes merely give the supplier additional checkbox options.


(v) Section 2(E) (Accreditation for Ambulatory Surgical Centers (ASCs) Only)


In Section 2(E), the ASC checks whether it is accredited. We are adding the following new checkbox to this section: “The ASC applied for or is pending accreditation”. This checkbox will impose no new burden; it simply gives the ASC an additional checkbox option in Section 2(E).


(vi) Deletion of Section 2(F) (Employer Terminating Employment Arrangement with One or More Physician Assistants (PAs))


Employers need no longer report whether they are terminating an employment arrangement with a PA. This is because PAs may now bill Medicare directly for the services they perform. They no longer need to bill the program through their employer.


When Section 2(F) was required, we roughly estimate that 5,000 employers per year (typically a Form CMS-855B-enrolled group practice that employed the PA) reported the termination of a PA arrangement via a Form CMS-855B COI. Section 2(F)’s removal means the burden estimate for the COI category will be reduced. The initial enrollment, enrolling with another MAC, revalidation, and reactivation categories are unaffected.



TABLE 7 – BURDEN CHANGE FOR REMOVAL OF SECTION 2(F)


Reason for Submittal

Number of

Respondents

Total Number of Responses

Time per Response (hours)

Total Annual Time (hours)

Cost of Completion Per Response (See Table 3)

Total Annual Cost ($)

Initial Enrollment

N/A

N/A

N/A

N/A

N/A

N./A

Enrolling with Another MAC

N/A

N/A

N/A

N/A

N/A

N/A

Revalidation

N/A

N/A

N/A

N/A

N/A

N/A

Reactivation

N/A

N/A

N/A

N/A

N/A

N/A

Reporting a Change of Information

(5,000)

(5,000)

0.333

(1,667)

19.02 (57.13 x 0.333)

(95,100)

Total

(5,000)

(5,000)

N/A

(1,667)

N/A

(95,100)


(vii) Section 3 (Final Adverse Actions)


We are revising Section 3’s list of final adverse actions (FAAs) to require the following to be reported:


  • Any felony conviction of the supplier’s managing organization, officer, or director.

  • Revising the FAA currently listed in Section 3(B)(2) to read: “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.”

  • Any misdemeanor conviction, under federal or state law, related to sexual abuse, sexual misconduct, inappropriate physical contact of another, or child pornography.


Since these FAAs are new to Section 3 and have not been previously reported, we have no historical data upon which we can accurately estimate of the burden of disclosure. For purposes of this ICR request only, we project that each year approximately 100 initially enrolling suppliers, 98 revalidating suppliers, 2 reactivating suppliers, and 25 enrolled suppliers (via a COI) will report one of these FAAs via the Form CMS-855B. We estimate that each disclosure will take 30 minutes. Table 8 outlines the burden change associated with our revision to Section 3.


TABLE 8 – BURDEN CHANGE FOR SECTION 3 REVISION – FINAL

ADVERSE ACTIONS


Reason for Submittal

Number of

Respondents

Total Number of Responses

Time per Response (hours)

Total Annual Time (hours)

Cost of Completion Per Response

Total Annual Cost ($)

Initial Enrollment

100

100

0.5

50

20.78 (41.56 x 0.5)

2,078

Enrolling with Another MAC

0

0

N/A

0

N/A

0

Revalidation

98

98

0.5

49

20.78 (41.56 x 0.5)

2,036

Reactivation

2

2

0.5

1

20.78 (41.56 x 0.5)

42

Reporting a Change of Information

25

25

0.5

13

28.57 (57.13 x 0.5)

714

Total

225

225

0.5

113

N/A

4,870



(viii) Section 4(A) (Practice Location Information)


Section 4(A) requires the supplier to identify via checkbox the type of facility in which it is located. A current checkbox option is “Home/Business Office for Administrative Use Only.” We are splitting this into separate “Home Office for………” and “Business Office for………” checkboxes. As we are merely dividing this checkbox into two options, no new burden is implicated.


(ix) Section 4(C)(2) (Practice Location Information – Electronic Records)

The supplier currently must disclose in Section 4(C)(2) the website at which any electronic records are stored. We are removing this data box and instead requiring the supplier to list the address and tax identification number of the company via which (if applicable) electronic records are stored. We believe that furnishing this address will take the supplier 15 minutes (0.25 hours) longer than furnishing the website address. Table 9 below outlines the projected burden associated with this change.


TABLE 9 – BURDEN CHANGE FOR SECTION 4(C) REVISION –

ELECTRONIC MEDICAL RECORDS


Reason for Submittal

Number of

Respondents

Total Number of Responses

Time per Response (hours)

Total Annual Time (hours)

Cost of Completion Per Response (See Table 3)

Total Annual Cost ($)

Initial Enrollment

13,578

13,578

0.25

3,395

10.39 (41.56 x 0.25)

141,075

Enrolling with Another MAC

14

14

0.25

4

10.39 (41.56 x 0.25)

145

Revalidation

8,100

8,100

0.25

2,025

10.39 (41.56 x 0.25)

84,159

Reactivation

2,535

2,535

0.25

634

10.39 (41.56 x 0.25)

26,339

Reporting a Change of Information

24,223

24,223

0.25

6,056

14.25 (57.13 x 0.25)

345,178

Total

48,450

48,450

0.25

12,114

N/A

596,896



(x) Section 4(H) (Reassignment of Benefits Information)


Reassignment information was previously collected via the Form CMS-855R. With the Form CMS-855R’s discontinuance, this data is now captured through the Form CMS-855I (for the physician/practitioner reassigning his/her benefits) and in new Section 4(H) of the Form CMS-855B (for the entity to which the individual is reassigning his/her benefits). Although the supplier burden associated with completing the Form CMS-855R has been eliminated, there will now be a Form CMS-855B burden for completing Section 4(H).


Section 4(H)(1) will capture the reassignor’s name, social security number, Medicare identification number, and National Provider Identifier (NPI). (Section 4(H)(2) will collect the primary and secondary practice locations at which the reassignor will render services on the reassignee’s behalf. These sections are optional, however, so no burden is involved.) We estimate that completion of Section 4(H)(1) will take 10 minutes (0.167 hours). Table 10 below addresses our burden estimates.


TABLE 10 – BURDEN CHANGE FOR SECTION 4(H) REVISION –

REASSIGNMENTS


Reason for Submittal

Number of

Respondents

Total Number of Responses

Time per Response (hours)

Total Annual Time (hours)

Cost of Completion Per Response (See Table 3)

Total Annual Cost ($)

Initial Enrollment

17,744

17,744

0.167

2,963

6.94 (41.56 x 0.167)

123,143

Enrolling with Another MAC

21

21

0.167

4

6.94 (41.56 x 0.167)

146

Revalidation

34,991

34,991

0.167

5,843

6.94 (41.56 x 0.167)

242,838

Reactivation

4,418

4,418

0.167

738

6.94 (41.56 x 0.167)

30,661

Reporting a Change of Information

33,014

33,014

0.167

5,513

9.54 (57.13 x 0.167)

314,954

Total

90,188

90,188

0.167

15,061

N/A

711,742



(xi) Section 5(A) (Organization with Ownership Interest and/or Managing Control – Identification Information)


Section 5(A) collects information regarding organizations that own or manage the supplier. The section currently has checkboxes via which the supplier must identify the organization’s interest in the supplier (e.g., managing control, partnership interest). We are adding more checkboxes to Section 5(A) that will help further clarify the organization’s interest. This will not impose additional burden on the supplier, for our change only affords the supplier more options for identifying its relationship with the supplier. It does not involve the submission of additional data.

(xii) Section 5(A) (Organization with Ownership Interest and/or Managing Control – Identification Information)


Section 5(A) currently captures the Medicare identification number (if issued) of the owning/managing organization(s). We are removing this data element from the Form CMS-855B because we believe it is no longer necessary. This will result in a burden reduction. We project that reporting this data took suppliers 15 minutes (0.25 hours). Table 11 outlines our burden reduction projections.



TABLE 11 – BURDEN CHANGE FOR SECTION 5(A) REVISION –

OWNERSHIP/MANAGEMENT


Reason for Submittal

Number of

Respondents

Total Number of Responses

Time per Response (hours)

Total Annual Time (hours)

Cost of Completion Per Response (See Table 3)

Total Annual Cost ($)

Initial Enrollment

(20,295)

(20,295)

0.25

(5,074)

10.39 (41.56 x 0.25)

(210,865)

Enrolling with Another MAC

(4)

(4)

0.25

(1)

10.39 (41.56 x 0.25)

(42)

Revalidation

(6,599)

(6,599)

0.25

(1,650)

10.39 (41.56 x 0.25)

(68,564)

Reactivation

(685)

(685)

0.25

(171)

10.39 (41.56 x 0.25)

(7,117)

Reporting a Change of Information

(21,755)

(21,755)

0.25

(5,439)

14.25 (57.13 x 0.25)

(310,009)

Total

(49,338)

(49,338)

0.25

(12,335)

N/A

(596,597)



(xiii) Section 6(A) (Individual with Ownership Interest and/or Managing Control – Identification Information – Telephone/Fax/E-mail Number)


Section 6(A) collects information regarding individuals who own or manage the supplier. We are adding the following data elements the supplier must furnish about these individuals’ telephone number, fax number, and email address. We estimate that it will take a supplier approximately 25 minutes to furnish this data. Table 12 outlines our burden estimates.



TABLE 12 – BURDEN CHANGE FOR SECTION 6(A) REVISION –

OWNERSHIP/MANAGEMENT


Reason for Submittal

Number of

Respondents

Total Number of Responses

Time per Response (hours)

Total Annual Time (hours)

Cost of Completion Per Response (See Table 3)

Total Annual Cost ($)

Initial Enrollment

42,083

42,083

0.4167

17,536

10.39 (41.56 x 0.4167)

437,242

Enrolling with Another MAC

37

37

0.4167

15

10.39 (41.56 x 0.4167)

384

Revalidation

41,608

41,608

0.4167

17,338

10.39 (41.56 x 0.4167)

432,307

Reactivation

5,761

5,761

0.4167

2,401

10.39 (41.56 x 0.4167)

59,857

Reporting a Change of Information

26,893

26,893

0.4167

11,206

14.25 (57.13 x 0.4167)

383,225

Total

116,382

116,382

0.4167

48,496

Varies

1,313,015



(xiv) Section 6(A) (Individual with Ownership Interest and/or Managing Control – Identification Information)


The section currently has checkboxes via which the supplier must identify its interest in the supplier (e.g., managing control, partnership interest). We are splitting the “Partnership Interest” checkbox into separate general partner and limited partner checkboxes to better identify the type of partnership interest. This will involve no new burden for suppliers.


(xv) Section 12 (Supporting Documentation Information)


Section 12 outlines certain documents the supplier must submit with their applications. We are adding several document types to this list. These newly listed documents are already typically submitted even though they are not specifically listed in Section 12. For this reason, we do not project an increased burden for our Section 12 additions.


(xvi) Section 13 (Contact Person Information)


Section 13, which is optional, permits the supplier to report an individual to whom the MAC can direct questions regarding the application submission. We are adding the following new data element to Section 13: “Relationship or Affiliation to Individual or Organization/Group (Spouse, Secretary, Attorney, Billing Agent, etc.)” However, as Section 13 is, again, optional, we are not projecting a burden estimate for this data element.


(xv) Section 15 (Certification Statement)


Consistent with the Form CMS-855R’s discontinuance and the collection of certain reassignment data via the Form CMS-855B, Section 15 now includes new data elements for the reassignor’s name, signature, and date of signature. We estimate that 17,798 reassignors per year will furnish their signature on the supplier’s initial enrollment application. It will take the reassignor three minutes to do so.


TABLE 13 – BURDEN CHANGE FOR SECTION 15 REVISION –

REASSIGNOR SIGNATURE


Reason for Submittal

Number of

Respondents

Total Number of Responses

Time per Response (hours)

Total Annual Time (hours)

Cost of Completion Per Response (See Table 3)

Total Annual Cost ($)

Initial Enrollment

17,798

17,798

0.05

890

11.35 (226.92 * x 0.05)

202,007

Enrolling with Another MAC

N/A

N/A

N/A

N/A

N/A

N/A

Revalidation

N/A

N/A

N/A

N/A

N/A

N/A

Reactivation

N/A

N/A

N/A

N/A

N/A

N/A

Reporting a Change of Information

N/A

N/A

N/A

N/A

N/A

N/A

Total

17,798

17,798

0.05

890

11.35

202,007


* Current Physician BLS wage.



(xvi) Attachment 2 (Independent Diagnostic Testing Facilities) (IDTFs)


We are adding a new element to Section B of Attachment 2 that requires the IDTF to list the serial numbers of the testing equipment it uses. We estimate that it will take each IDTF 20 minutes to do so. Table 14 outlines our burden estimates.



TABLE 14 – BURDEN CHANGE FOR ATTACHMENT 2 REVISION –

IDTF SERIAL NUMBERS


Reason for Submittal

Number of

Respondents

Total Number of Responses

Time per Response (hours)

Total Annual Time (hours)

Cost of Completion Per Response (See Table 3)

Total Annual Cost ($)

Initial Enrollment

339

339

0.333

113

13.84 (41.56 x 0.333)

4,692

Enrolling with Another MAC

1

1

0.333

0

13.84 (41.56 x 0.333)

0

Revalidation

337

337

0.333

112

13.84 (41.56 x 0.333)

4,664

Reactivation

47

47

0.333

16

13.84 (41.56 x 0.333)

650

Reporting a Change of Information

636

636

0.333

212

19.02 (57.13 x 0.333)

12,097

Total

1,360

1,360

0.33

453

Varies

22,103



(xvii) Attachment 2 (Independent Diagnostic Testing Facilities) (IDTFs)


We are adding a new element to Section D of Attachment 2 that requires the IDTF to identify the state in which their technicians are licensed or certified. We estimate that it will take each IDTF 8 minutes to report this information. Table 15 outlines our burden estimates.


TABLE 15 – BURDEN CHANGE FOR ATTACHMENT 2 REVISION –

IDTF TECHNICIAN LICENSURE


Reason for Submittal

Number of

Respondents

Total Number of Responses

Time per Response (hours)

Total Annual Time (hours)

Cost of Completion Per Response (See Table 3)

Total Annual Cost ($)

Initial Enrollment

339

339

0.133

45

5.53 (41.56 x 0.133)

1,875

Enrolling with Another MAC

1

1

0.133

0

5.53

(41.56 x 0.133)

0

Revalidation

337

337

0.133

45


5.53

(41.56 x 0.133)

1,864

Reactivation

47

47

0.133

6

5.53

(41.56 x 0.133)

260

Reporting a Change of Information

636

636

0.133

85

7.60

(57.13 x 0.133)

4,834

Total

1,360

1,360

0.133

181

Varies

8,833



d. Total Burden Change


Table 16 outlines the total, combined burden change associated with the revisions described in Section 12(c) above.



TABLE 16 – TOTAL BURDEN CHANGE FOR ALL REVISIONS ADDRESSED

IN SECTION 12(C)


Number of Respondents






Number of Responses

Burden per Response (hours)

Total Annual Burden (hours)

Hourly Labor

Cost of

Reporting ($) (includes 100% fringe benefits) *

Total Cost

($)

Deletion of Section 2(F) – Physician Assistant Employer


(5,000)

(5,000)

0.333

(1,667)

19.02

(95,100)

Section 3 – Additional of Final Adverse Actions


225

225

0.50

113

Varies

4,870

Section 4(C)(2) – Electronic Records


48,450

48,450

0.25

12,114

Varies

596,896

Section 4(H)(1) – Reassignment of Benefits Information


90,188

90,188

0.167

15,061

Varies

711,742

Section 5(A) – Removal of Medicare Identification Number


(49,338)

(49,338)

0.25

(12,335)

Varies

(596,597)

Section 6(A) – Addition of Telephone/E-mail/Fax


116,382

116,382

0.4167

48,496

Varies

1,313,015

Section 15 – Reassignor Signature


17,798

17,798

0.05

890

11.35

202,007

Attachment 2 – IDTF Serial Numbers


1,360

1,360

0.333

453

Varies

22,103

Attachment 2 – IDTF Technician State of Licensure or Certification


1,360

1,360

0.133

181

Varies

8,833

Total


221,425

221,425

Varies

63,306

Varies

2,167,769



Table 17 breaks down by application submission reason the total, combined burden change associated with the revisions described in Section 12(c) above.



TABLE 17 – TOTAL FORM CMS-855B BURDEN CHANGE BREAKDOWN BY

APPLICATION SUBMISSION REASON


Number of Respondents






Number of Responses

Burden per Response (hours)

Total Annual Burden (hours)

Hourly Labor

Cost of

Reporting ($) (includes 100% fringe benefits) *

Total Cost

($)

Initial Enrollment

71,686

71,686

Varies

19,918

Varies

701,247


Enrolling with Another MAC

70

70

Varies

22

Varies

633


Revalidation

78,872

78,872

Varies

23,762

Varies

699,304


Reactivation

12,125

12,125

Varies

3,625

Varies

110,692


Reporting a Change of Information

58,672

58,672

Varies

15,979

Varies

655,893

TOTAL

221,425

221,425

Varies

63,306

Varies

2,167,769




We emphasize with respect to the “Respondents” category, however, that the 221,425 figure therein does not mean that our changes will result in, for instance, the submission of 71,686 additional initial enrollment applications and 12,125 reactivations each year – in both cases roughly twice what we receive as reflected in Table 6 above. The Respondents category simply reflects the number of instances where a supplier will furnish one of the newly requested or revised data elements.



  1. Cost to Respondents (Capital)


There are no capital costs associated with this collection.



  1. Cost to Federal Government


14.1 MACs


We anticipate costs for the MACs for processing the above-mentioned Form CMS-855B changes. We projected in Table 16 an annual supplier burden of 63,306 hours. Given our experience, we estimate it will take the MACs a similar amount of time to process this data.


The applicable MAC hourly is wage equivalent to a GS-9, Step 5 (Washington/Baltimore/Arlington locality), which is $37.15. (See https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/24Tables/html/DCB_h.aspx.) This results in an annual increase in MAC costs of $2,351,818 (or 63,306 x $37.15).


  1. Annual Changes in Burden/Program Changes


Current PECOS data suggests that the number of respondents in each of the categories that make up the 855 form have increased which resulted in a total increase of 59,336 respondents. In addition, several revisions are being made to the 855 form which also impacted the increase of burden. Thus, burden has increased from 171,885 to 299,550 hours. As shown in Table 17, we project the following increases in annual burden for the following Form CMS-855B application categories:


Form CMS-855B


Respondents

Responses

Hours

Costs

Initial Enrollment

71,686

71,686

19,918

701,247


Enrolling with Another MAC

70

70

22

633


Revalidation

78,872

78,872

23,762

699,304


Reactivation

12,125

12,125

3,625

110,692


Reporting a Change of Information

58,672

58,672

15,979

655,893



  1. Publication/Tabulation


All information collected will be kept private in accordance with 5 U.S.C. 552(b)(4), Executive Order 12600, and 45 CFR 155.260 (Privacy and Security of Personally Identifiable Information). Privileged or confidential commercial or financial information is protected from public disclosure by federal law.



  1. Expiration Date


We are planning on displaying the expiration date.



18. Certification Statement


There are no exceptions to the certification statement.



B. Collections of Information Employing Statistical Methods


This collection does not employ statistical methods.


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