Medicare Program Integrity Manual (Pub. 100-08), Ch. 10 § 10.3.1.2.9
(Delegated Officials) - Form CMS-855B
10.3.1.2.9 – Section 16 (Delegated Officials) - Form CMS-855B
(Rev. 13355; Issued: 08-13-25; Effective: 05-05-25; Implementation: 05-05-25)
A. General Requirements
A delegated official is an individual to whom an authorized official listed in the Certification
Statement section of the Form CMS-855B delegates the authority to report changes and updates
to the supplier’s enrollment record or to sign revalidation applications. The delegated official’s
signature binds the organization both legally and financially, as if the signature were that of the
authorized official. Before the delegation of authority is established, the only acceptable
signature on the enrollment application to report updates or changes to the enrollment
information is that of an authorized official currently on file with Medicare. The delegated
official must be an individual with an “ownership or control interest” in (as that term is defined
in § 1124(a)(3) of the Social Security Act) or be a W-2 managing employee of the supplier.
Section 1124(a)(3) defines an individual with an ownership or control interest as:
• A five percent direct or indirect owner of the supplier,
• An officer or director of the supplier (if the supplier is a corporation), or
• Someone with a partnership interest in the supplier if the supplier is a partnership
The delegated official must be a delegated official of the supplier, not of an owning organization,
parent company, chain home office, or management company. One cannot use a status as a W-2
managing employee of the supplier’s parent company, management company, or chain home
office as a basis for the individual’s role as the supplier’s delegated official.
The supplier must complete the Ownership Interest and Managing Control Information for
Individuals section of the Form CMS-855B for all delegated officials.
A delegated official has no authority to sign an initial application. However, the delegated
official may (i) sign a revalidation application and (ii) sign off on changes/updates submitted in
response to a contractor’s request to clarify or submit information needed to continue processing
the supplier's initial application.
Delegated officials may not delegate their authority to any other individual. Only an authorized
official may delegate the authority to make changes and/or updates to the supplier's Medicare
data or to sign revalidation applications.
For purposes of the Delegated Officials information captured in the Delegated Official section
only, the term "managing employee" means any individual (including a general manager,
business manager, or administrator) who exercises operational or managerial control over the
provider, or who conducts the day-to-day operations of the supplier. However, this does not
include persons who, either under contract or through some other arrangement, manage the day-
to-day operations of the supplier but who are not actual W-2 employees. For instance, suppose
the provider hires Smith as an independent contractor to run its day-to-day-operations. Under
the definition of "managing employee" in the Ownership Interest and Managing Control
Information for Individuals section of the Form CMS-855B, Smith would have to be listed in
that section. Yet under the Delegated Officials section definition (as described above), Smith
cannot be a delegated official because Smith is not an actual W-2 employee of the provider.
Independent contractors are not considered "managing employees" under the Delegated Officials
section of the Form CMS-855B.
B. W-2 Form
Unless the contractor requests it to do so, the supplier need not submit a copy of the
owning/managing individual’s W-2 to verify an employment relationship.
C. Number of Delegated Officials
The supplier can have as many delegated officials as it chooses. It also need not have any
delegated officials at all. If the supplier lists no delegated officials, however, the authorized
official(s) remains the only individual(s) who can report changes and/or updates to the supplier's
enrollment data.
D. Effective Date
The effective date in PECOS for a delegated official should be the date of signature.
E. SSN
To be a delegated official, the person must have and submit an SSN. An individual may not use
an ITIN in lieu of an SSN in this regard.
F. Deletion of a Delegated Official
For delegated official deletions, documentation verifying that the person no longer is or qualifies
as a delegated official is not required. In addition, the delegated official’s signature is
unnecessary.
G. Delegated Official Not on File
If the supplier submits a change of information (e.g., change of address) and the delegated
official signing the form is not on file, the contractor shall ensure that:
(i) The person meets the definition of a delegated official,
(ii) The supplier completes the Individual Ownership and/or Managing Control section of the
Form CMS-855B for that person, and
(iii) An authorized official signs off on the addition of the delegated official.
(NOTE: The original change request and the addition of the new official constitute a single
change request (i.e., one change request encompassing two different actions) for purpose of
enrollment processing and reporting)).
H. Signature on Paper Application
If the provider submits a paper Form CMS-855B change request, the contractor may accept a
delegated official’s signature in the Certification Statement or Delegated Official section of the
Form CMS-855B.
I. Telephone Number
The delegated official’s telephone number can be left blank. No further development is needed