Reassignment of Medicare Benefits Via the Form CMS-855I

10.3.1.4 - Reassignment of Medicare Benefits Via the Form CMS-855I (Rev. 13355; Issued: 08-13-25; Effective: 05-05-25; Implementation: 05-05-25) A. Background Consistent with 42 CFR § 424.80(b)(1) and (b)(2) and Pub. 100-04, Chapter 1, sections 30.2.1(D) and (E) and 30.2.6 and 30.2.7, Medicare may pay: (1) a physician or other provider’s or supplier’s employer if the provider or supplier is required, as a condition of employment, to turn over to the employer the fees for the individual’s services; or (2) an entity (i.e., a person, group, or facility) that is enrolled in the Medicare program for services furnished by a physician or other provider or supplier under a contractual arrangement with that entity. This means that Part A and Part B entities other than physician/practitioner group practices can receive reassigned benefits, assuming the requirements for a reassignment exception are otherwise met. Reassignments of benefits are now facilitated via the Form CMS-855I. The Form CMS-855R has been discontinued. B. General Reassignor Policies An individual who renders Medicare Part B services and seeks to reassign benefits to an eligible entity should complete Sections 4(F)(1) and (2) of the Form CMS-855I for each party eligible to receive reassigned benefits; the individual must be enrolled in Medicare as a physician/practitioner prior to reassigning benefits. The applicable sections of the Form CMS- 855I (e.g., Section 1(A) (Reason for Submittal); Section 1(B) (Reassignment of Benefits checkbox); Sections 4(F)(1) and (2); Section 15; etc.) must also be completed for any individual who is adding, terminating, changing an existing reassignment. (Note that Section 4(F)(3) is optional.) The individual can report multiple new, changed, or terminated reassignments to parties with the same or different employer identification numbers (EINs) on a single Form CMS-855I by submitting separate Section 4(F)s and Section 15(C)s with the appropriate reassignee signatures. (For instance, if a physician is reassigning to Groups A, B, and C, an authorized/delegated official of A, B, and C, respectively, must sign a separate Section 15(C).) The contractor shall issue one approval letter using the applicable model letter in sections 10.7.6(D) and 10.7.6(M) of chapter 10. For reassignment terminations, the effective date of termination as indicated on the Form CMS- 855I is the day after the effective date of termination. Payment will no longer be made to the reassignee the day after the termination effective date. To illustrate, suppose a physician submits a Form CMS-855I to terminate a reassignment to a group. June 30, 2025, is listed as the termination date. The termination effective date listed in PECOS and any correspondence to the supplier should be July 1, 2025. There could be rare situations where an unenrolled individual seeks to reassign benefits and submits only Section 4(F) of the Form CMS-855I. The contractor in this situation shall develop for an initial enrollment application from the individual. The contractor need not verify whether the reassigning individual is a W-2 employee or a 1099 contractor. Regarding reassignment and revoked or deceased physicians, see section 10.6.17(G)(1) of this chapter. C. Policies Concerning Reassignees 1. Site of Service Per Pub. 100-04, chapter 1, section 30.2.7, a reassignment of benefits to any eligible party is permitted regardless of where the service was rendered or whether the party owns or leases that location. As such, the contractor need not verify the reassignee’s ownership or leasing arrangement with respect to the reassignment. 2. Organization/Group Receiving the Reassigned Benefits The most common reassignment situation is a physician/practitioner who reassigns benefits to a physician/practitioner group. Here, the reassignee’s authorized or delegated official must sign Section 15(C) of the reassignor’s Form CMS-855I. 3. Individual Receiving Reassigned Benefits An individual can receive reassigned benefits. This can occur, for instance, when a physician/practitioner reassigns benefits to a physician/practitioner who is either (1) a sole proprietor or (2) the sole owner of an entity listed in the Business Information section of the Form CMS-855I. Here, the only required forms are separate Form CMS-855Is from the reassignor and the reassignee. (No Form CMS-855B or Form CMS-855A is involved.) The reassignee must sign Section 15(C) of the reassignor’s Form CMS-855I. (Note that Section 15(C) applies to all reassignees, regardless of whether they are organizations or individuals. In the former case, the organization’s authorized/delegated official must sign Section 15(C); with the latter, the individual reassignee must sign.) The contractor shall follow the instructions in Pub. 100-04, Chapter 1, sections 30.2 – 30.2.16 to ensure that the reassignee is indeed eligible to receive reassigned benefits. 4. Additional Information If the reassignee is not enrolled in Medicare, said party must complete, as applicable, an initial Form CMS-855B, Form CMS-855A, or Form CMS-855I. Benefits are reassigned to a provider or supplier, not to the provider/supplier’s practice location(s). As such, the reassignor need not update the individual’s reassignment data on the Form CMS-855I each time the reassignee adds a practice location. When a group practice adds a new practice location, each physician/practitioner who reassigns to the group and wants to bill from this new location must have a new PTAN if the group is issued a new PTAN. (The group will only be issued a new PTAN if the new location is in a separate fee locality.) D. Additional Signature Policies 1. Who Must Sign For initial/new reassignments, both the reassignor and reassignee (or an authorized/delegated official of the latter) must sign, respectively, Section 15(B) and (C) of the reassignor’s Form CMS-855I. If either required signature is missing, the contractor shall develop for it. For changes in reassignment data or for reassignment terminations (and as similar situations were handled with the Form CMS-855R), only the reassignor or reassignee must submit the termination or applicable changed information in Section 4(F) and sign Section 15(B) or (C) (as applicable). 2. Official On/Not on File An authorized/delegated official who signs Section 15(C) of the Form CMS-855I must be currently on file with the contractor as such. If this is a new enrollment --- with a joint submission of the Form(s) CMS-855A or CMS 855B and Form CMS-855I --- the person must be listed on the Form CMS-855A or Form CMS-855B as an authorized/delegated official. There may be situations where a Form CMS-855I is submitted and the reassignee is already enrolled in Medicare via the Form CMS-855B. However, the authorized/delegated official is not on file. In this case, the contractor shall develop for a Form(s) CMS-855A or CMS-855B change request that adds the new authorized/delegated official. 3. Development Needed If the contractor must develop for information in Section 4(F)(1) or (2), the following apply: (i) Initial reassignments (as part of an initial Form CMS-855I or a Form CMS-855I change of information that adds a new reassignment): Both the reassignor and reassignee (or, for entities, an authorized/delegated official thereof) must sign any certification statement that must accompany the reassignor’s response. (ii) All other transactions – Only the reassignor or reassignee need sign any required certification statement. 4. Other Signature Policies The contractor shall follow all other applicable signature policies (e.g., form of signature) outlined in section 10.3.1.3.6 of this chapter. 5. Processing Alternatives As applicable, the contractor may apply the processing alternatives identified in section 10.3.1.3.7 to the Section 4(F) data. E. Inter-Jurisdictional Reassignments If a reassignor is reassigning benefits to a reassignee located in another contractor jurisdiction (a permissible practice), the principles in this section 10.3.1.4(E) apply unless another CMS directive states otherwise. 1. The reassignor must be properly licensed or otherwise authorized to perform services in the state in which the individual has the practice location. The practice location can be an office or even the individual’s home (for example, a physician interprets test results in the physician’s home for an independent diagnostic testing facility). 2. The reassignor need not – pursuant to the reassignment - enroll in the reassignee’s contractor jurisdiction nor be licensed/authorized to practice in the reassignee’s state. If the reassignor will be performing services within the reassignee’s state, the reassignor must enroll with the contractor for (and be licensed/authorized to practice in) that state. 3. The reassignee must enroll in the contractor jurisdictions in which (1) it has its own practice location(s), and (2) the reassignor has the practice location(s). In Case (2), the reassignee: (i) Shall identify the reassignor’s practice location as a practice location on its Form CMS-855B or Form CMS-855I. (ii) Shall select the practice location type as “Other health care facility” and specify “Telemedicine location” in the Practice Location Information of its Form CMS-855. (iii) Need not be licensed/authorized to perform services in the reassignor’s state. To illustrate, suppose Dr. Smith is in Contractor Jurisdiction X and is reassigning benefits to Jones Medical Group in Contractor Jurisdiction Y. Jones must enroll with X and with Y. Jones need not be licensed/authorized to perform services in Dr. Smith’s state. However, in the Practice Location Information section of the Form CMS- 855B it submits to X, Jones must list Dr. Smith’s location as its practice location. F. Reassignment to CAHs Reassignment to a Part A provider or supplier might occur when: (1) a physician or practitioner reassigns benefits to a hospital, skilled nursing facility, or critical access hospital billing under Method II (CAH II); or (2) a nurse practitioner reassigns to a CAH II. If the entity receiving the reassigned benefits is not a CAH II, it must enroll with the contractor via a Form CMS-855B, and the physician/practitioner reassigning benefits must complete and submit a Form CMS-855I. If the entity receiving the reassigned benefits is a CAH II, the entity need not complete a separate Form CMS-855B to receive reassigned benefits. The physician/practitioner can reassign benefits directly to the CAH II’s Part A enrollment. The distinction between CAHs billing Method I vs. Method II only applies to outpatient services. It does not apply to inpatient services. Under Method I: • The CAH bills for facility services • The physicians/practitioners bill separately for their professional services Under Method II: • The CAH bills for facility services • If a physician/practitioner has reassigned benefits to the CAH, the CAH bills for that particular physician’s/practitioner’s professional service • If a CAH has elected Method II, the physician/practitioner need not reassign benefits to the CAH. For those physicians/practitioners who do not reassign their benefits to the CAH, the CAH only bills for facility services and the physicians/practitioners separately bill for their professional services (akin to Method I). Although physicians and non-physician practitioners are not required to reassign their benefits to a CAH that bills Method II, doing so allows them to participate in the Electronic Health Records (EHR) Incentive Program for Eligible Professionals (EPs). In this scenario, the Form CMS-855I shall be submitted to the Part B MAC and the Form CMS- 855A submitted to the Part A MAC. The Part B MAC is responsible for reassigning the individual to the Part A entity. The reassignment to the Part A entity shall only occur if the Form CMS-855A for the CAH II has been finalized. This can be determined by viewing PECOS to identify if an approved enrollment exists for the CAH II. If one does not, the Part B MAC shall return the Form CMS-855I to the provider on the ground that it is inapplicable to the transaction in question (i.e., the Form CMS- 855A has not been finalized). If an enrollment record exists but is pending state/SOG review, the Part B MAC shall contact the Part A MAC to determine if state/SOG Location (as applicable) approval has been received but not yet updated in PECOS prior to returning the applications. G. Reassignments Related to Revoked or Deactivated Reassignee The contractor shall end-date in PECOS all reassignment associations and the associated Provider Transaction Access Numbers (PTANs) when revoking or deactivating an individual or organization (reassignee) that is receiving reassigned benefits from an individual practitioner. The end-date shall be the same as the effective date of the revocation or deactivation; this will ensure the appropriate end-date in the Multi-Carrier System (MCS) and prevent improper use of those PTANs. However, the contractor shall not deactivate the individual practitioner’s (reassignor’s) enrollment record even if (1) the reassigned PTAN is the only PTAN on the individual’s enrollment record and/or (2) no other active locations exist (private practice locations or reassignments); the contractor shall allow the practitioner’s/reassignor’s enrollment record to remain in an approved status. When sending a deactivation, revocation, or voluntary withdrawal letter to the deactivated or revoked non-certified Part B supplier, said letter shall include the following language: “Please notify all physician assistants and/or group members who reassign benefits to your organization that, in accordance with 42 CFR §424.540(a)(2), their Medicare enrollment status may be deactivated if they fail to update their enrollment record within 90 calendar days.” H. Group and Reassignment Reactivation If a group practice submits a reactivation application after being deactivated for non-response to a revalidation request, the contractor shall reactivate the group’s reassignments when the group’s reactivation application has been approved; Form CMS-855I applications for the reassignments are not required. The effective dates assigned to the reassigned providers shall align with the group’s effective date per existing reactivation instructions. (This section 10.3.1.4(H) only applies to deactivations based on a non-response to a revalidation request.) I. Additional Information The contractor: • Shall follow this chapter’s existing instructions (and all other applicable CMS guidance) for validating information furnished by a physician/practitioner on the Form CMS-855I, including any reassignment data in Sections 4(F)(1) and (2). • Shall follow the instructions in section 10.6.2 of this chapter regarding the application of effective dates.