Medicare Program Integrity Manual (Pub. 100-08), Ch. 15.4
Processing Guide-855O
Length: 3,769 wordsOfficial source
Disclaimer: The information contained in this guide is to assist providers/suppliers in completing
the Form CMS-855O application and MACs in processing Form CMS-855O application.
Processing the CMS-855O Medicare
Enrollment Application – Enrollment for
Eligible Ordering, Certifying Physicians,
and Other Eligible Professionals
Disclaimer: The information contained in this guide is to assist providers/suppliers in completing
the Form CMS-855O application and MACs in processing Form CMS-855O application.
Contents
General Information ........................................................................................................................................... 3
Section 1: Basic Information ............................................................................................................................... 4
A - Reason for Submitting this Application ..................................................................................................... 5
B - Reason you are Enrolling to Order and Certify .......................................................................................... 5
Section 2: Identifying Information ..................................................................................................................... 6
A – Personal Information ................................................................................................................................ 6
B – Educational Information ........................................................................................................................... 6
C – License/Certification/Registration Information ........................................................................................ 7
Section 3: Final Adverse Legal Action ................................................................................................................ 8
Section 4: Medical Specialty Information ........................................................................................................... 8
A – Physician Specialty .................................................................................................................................... 8
B – Eligible Professional or Other Eligible Professional or Other Non-Physician Type Specialty Type ........... 8
Section 5: Important Address Information ........................................................................................................ 9
Section 6: Contact Person Information .............................................................................................................. 9
Section 7: Penalties for Falsifying Information on this Application ................................................................. 10
Section 8: Certification Statement and Signature ............................................................................................ 10
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Instructions for CMS-855O Medicare Enrollment Application – Enrollment for Eligible Ordering, Certifying
and Prescribing Physicians, and Other Eligible Professionals
General Information
Most physicians and eligible professionals (as defined in section 1848(K)(3)(B) of the Social
Security Act) enroll in the Medicare program to be reimbursed for the covered services they
furnish to Medicare beneficiaries. However, with the implementation of Section 6405 of the
Affordable Care Act, CMS requires certain physicians and eligible professionals (hereafter
referred to as providers) to enroll in the Medicare program for the sole purpose of ordering or
certifying items or services for Medicare beneficiaries. These providers do not and will not send
claims to a Medicare Administrative MAC (MAC) for the services they furnish. The providers
who may enroll in Medicare solely for the purpose of ordering and certifying include those who
are:
• Doctors of Medicine or Osteopathy
• Doctors of Dental Medicine
• Doctors of Dental Surgery
• Doctors of Podiatric Medicine
• Doctors of Optometry
• Physician Assistants
• Certified Clinical Nurse Specialists
• Nurse Practitioners
• Clinical Psychologists
• Certified Nurse Midwifes
• Clinical Social Workers
• Licensed Residents (as defined in 42 C.F.R. section 413.75(b)) in an approved
medical residency program
• Retired Physicians who are licensed
These providers can enroll for the sole purpose of ordering or certifying items or services for
Medicare beneficiaries by completing the Form CMS-855O via paper or the Internet-based
Provider Enrollment, Chain and Ownership System (PECOS) process. To obtain additional
information on Internet-based PECOS, refer to http://www.cms.gov/Medicare/Provider-
Enrollment-and- Certification/MedicareProviderSupEnroll/InternetbasedPECOS.html.
In lieu of Internet-based PECOS, the most current version of the Form CMS-855O (January 2017)
shall be completed by the providers. If an outdated version of the application is submitted, the
MACs shall return any Form CMS-855O applications submitted on the previous version (01/13) to
the provider/supplier with a letter explaining the CMS-855O has been updated and the supplier
must submit the current version of the CMS-855O (01/17). To obtain the current version of the
form, refer to http://www.cms.gov/MedicareProviderSupEnroll.
It is important to observe that providers that complete the Form CMS-855O do not and will not
send claims to their MAC for services they furnish. These providers are not given Medicare
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Instructions for CMS-855O Medicare Enrollment Application – Enrollment for Eligible Ordering, Certifying
and Prescribing Physicians, and Other Eligible Professionals
billing privileges for the purpose of submitting claims to Medicare directly for services that they
furnish to beneficiaries.
The ordering and certifying effective date is the date the MAC receives the CMS-855O
application.
NOTE: Only one Form CMS-855O submission is required which will allow the provider to
order, certify nationwide. Multiple Form CMS-855O submissions are not required. The provider
need not submit a Form CMS-460, a Form CMS-588, or an application fee with his or her Form
CMS-855O.
Providers shall submit their CMS-855O applications to the MAC that serves there geographic
jurisdiction. To find out the MAC that serves your jurisdiction, refer
to https://www.cms.gov/Medicare/Provider-Enrollment-and-
Certification/MedicareProviderSupEnroll/Downloads/contact_list.pdf.
However, since the CMS-855O is a national enrollment, providers who relocate to another state
are not required to dis-enroll in the current state and re-enroll in the new state. The MAC that
maintains the CMS-855O enrollment in the Provider Enrollment Chain and Ownership System
(PECOS) is responsible for processing the change of information, even if the provider is
relocating to a state outside of their jurisdiction. If any new licenses and/or certifications are
obtained as a result of the provider’s relocation, the MACs shall ensure that the updated
information is captured in the provider’s enrollment record.
Once enrolled, the provider will be listed on a CMS database located at http://Data.cms.gov and
will be deemed eligible to order and certify services and items for Medicare beneficiaries.
If the provider’s Form CMS-855O has been approved and he/she later wants to obtain Medicare
billing privileges, the provider must complete the Form CMS-855I in order to receive Medicare
billing privileges.
If the provider has an approved Opt Out affidavit and now wants to be ordering/certifying only,
the provider will need to notify the MAC they wish to term the Opt Out status, prior to
completing the CMS-855O. Please be aware that the Opt Out period must be exhausted prior to
enrollment.
Section 1: Basic Information
All information on the Form CMS-855O is required with the exception of fields specifically
marked as “optional”.
The following general alternatives are applicable to all sections of the Form CMS-855O,
unless otherwise specified:
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Instructions for CMS-855O Medicare Enrollment Application – Enrollment for Eligible Ordering, Certifying
and Prescribing Physicians, and Other Eligible Professionals
1. Information Disclosed Elsewhere - If a data element on the supplier’s Form CMS-855O
application is missing but the information is disclosed (1) elsewhere on the application or
(2) in the supporting documentation submitted with the application, the MAC need not
obtain the missing data via an updated Form CMS-855O page and a newly-signed
certification statement; no further development – not even by telephone – is required. The
following information, however, must be furnished in the appropriate section(s) of the
Form CMS- 855O, even if the data is identified elsewhere on the form or in the supporting
documentation:
a. Any final adverse action data requested in section 3
b. Legal names
c. Social Security Number (SSN)
d. NPI-legacy number combinations in section 2 (if applicable)
A - Reason for Submitting this Application
This section identifies the reason for the application submission. With the exception of the
voluntarily withdrawing checkbox, any blank checkboxes in Section 1 can be verified through
any means chosen by the MAC (e.g., e-mail, telephone, fax).
You are enrolling for the sole purpose of ordering/certifying
o Provider checks this box if he/she is enrolling for the sole purpose of ordering
and certifying items and/or services to beneficiaries in the Medicare program.
o All sections of the application must be completed.
You are currently enrolled solely to order and certify and are updating your
information
o Provider checks this box if he/she is enrolled for the sole purpose of ordering and
certifying items and/or services to beneficiaries in the Medicare program but is
making a change in their enrollment information.
o Section 2A must be completed with the physician or eligible professional’s
personal information and all other applicable sections, including section 8.
You are voluntarily withdrawing your Medicare enrollment to solely order and
certify
o Provider checks this box if he/she no longer wants to be enrolled for the
sole purpose of ordering and certifying items and/or services to
beneficiaries in the Medicare program.
o Section 2A must be completed with the physician or eligible professional’s
personal information and all other applicable sections, including section 8.
B - Reason you are Enrolling Solely to Order or Certify
This section identifies the reason the provider is registering solely to order, certify. Only one
reason should be checked. If a reason is not identified, the MAC can verify the information
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Instructions for CMS-855O Medicare Enrollment Application – Enrollment for Eligible Ordering, Certifying
and Prescribing Physicians, and Other Eligible Professionals
through any means chosen (e.g., e-mail, telephone, fax).
Section 2: Identifying Information
A – Personal Information
The provider must provide all applicable information in this section. The MAC shall verify all
of the information on the Form CMS-855O to include:
The name, date of birth and social security number coincides with the information on
the individuals Social Security record. This information will be validated against the
Social Security Administration (SSA).
The Medicare Identification Number (or PTAN) (if issued) of the provider should be
listed in the Medicare Identification Number field. If the provider is submitting an initial
enrollment application a PTAN need not be listed; the provider can enter the word “n/a”
in this field or leave the field blank since providers who enroll to order and certify will
not be assigned a PTAN.
NPI of the provider should be reflected in the National Provider Identifier field; it
should match the information provided to the National Plan and Provider Enumeration
System (NPPES) and must be a Type 1 NPI. NPPES can be accessed by visiting
https://nppes.cms.hhs.gov/NPPES/Welcome.do.
If any of the required information is not supplied, the MAC shall send a development
request to the provider/contact person to obtain the missing data except for “Type of Other
Name” and “Gender” which can be captured orally.
Reviewing the Medicare Exclusion Database (MED) and System for Award
Management (SAM) to ensure that the provider is not excluded or debarred.
If, at any time during the verification process, the MAC needs additional or clarifying information
from the provider, it shall follow existing CMS instructions for obtaining said data (e.g., sending a
developmental letter). The information must be furnished to the MAC within 30 calendar days of
the MAC’s request.
B – Educational Information
The provider must provide their Medical School/Professional School information in this section
along with their year of graduation. If the Form CMS-855O lacks the Medical or Professional
School and/or the year of graduation, but the information is disclosed in the supporting
documentation submitted with the application or already exists in PECOS, no further development
is needed by the MAC.
If the information is not given, found in the supporting documentation or PECOS, the MAC
shall send a development request to the provider/contact person to obtain the missing data. To
the maximum extent possible, the MAC may use means other than the provider’s submission
of documentation- such as a State or school Web site - to verify the Medical
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Instructions for CMS-855O Medicare Enrollment Application – Enrollment for Eligible Ordering, Certifying
and Prescribing Physicians, and Other Eligible Professionals
School/Professional School information.
C – License/Certification/Registration Information
The provider shall complete this section listing their applicable license, certifications and
registrations. The MAC shall verify that the provider meets the requirements for his/her supplier
type, is licensed and/or certified to furnish services and is of a supplier type that can legally order
or certify. The only licenses that must be submitted with the application are those required by
Medicare or the state to function as the supplier type in question.
When processing a non-physician practitioner’s (NPP) application, the MAC need not
automatically request a copy of the NPP’s degree or diploma (if it is not submitted) if his or her
education can be verified through other authorized means; requesting a copy of the degree or
diploma should only be done if educational information cannot otherwise be verified. If the
provider submits a copy of the applicable license, certification, registration or degree but fails to
complete the applicable section of Form CMS-855O, the section need not be completed if the data
in question can be verified on the license/certification/registration itself or via any of the
mechanisms at the MACs disposal.
If the MAC is aware that a particular state does not require license/certification and the “Not
Applicable” boxes are not checked in Section 2C, no further development is needed.
MACs shall process form CMS-855O applications where the provider has relocated to another
state. Since the form CMS-855O is a national enrollment, providers who relocate to another state
are not required to dis-enroll in the current state and re-enroll in the new state. The MAC that
maintains the form CMS-855O enrollment in the Provider Enrollment Chain and Ownership
System (PECOS) is responsible for processing the change of information, even if the provider is
relocating to a state outside of their jurisdiction. If any new licenses and/or certifications are
obtained as a result of the provider’s relocation, the MACs shall ensure that the updated
information is captured in the provider’s enrollment record.
The provider shall enter their Drug Enforcement Agency (DEA) Registration Information, if
applicable. If the DEA fields are not completed at all on the application, meaning no information
was entered into this section, MACs shall assume that the DEA information is not applicable and
are not required to develop. If the provider partially completed the section, MACs shall obtain the
missing information elsewhere on the CMS-855 application, in the supporting documentation, if
available, or using the DEA sources available to them; otherwise, the MAC is required to develop.
DEA certificates need not be submitted if the applicable DEA information was furnished on
the Form CMS-855O application. Similarly, if the aforementioned certificates are furnished
but the applicable CMS-855 sections are blank, no further development is needed by the MAC.
Section 3: Final Adverse Legal Action
This section captures information on final adverse legal actions, such as convictions, exclusions,
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Instructions for CMS-855O Medicare Enrollment Application – Enrollment for Eligible Ordering, Certifying
and Prescribing Physicians, and Other Eligible Professionals
revocations, and suspensions. The provider shall refer to the instructions in Section 3 for the
types of final adverse legal actions that must be reported. All applicable final adverse actions
must be reported in this section regardless of whether any records were expunged or any appeals
are pending. If a final adverse legal action is disclosed in this section, the provider must furnish
documentation concerning the type and date of the action, what court(s) and law enforcement
authorities were involved, and how the adverse action was resolved. The documentation must be
furnished regardless of whether the adverse action occurred in a state different from that in
which the provider seeks enrollment or is enrolled. With the exception of any federal/state
felony convictions within the preceding 10 years, identified in Section 3A1, all final adverse
actions must be reported regardless of when they occurred.
If the final adverse legal action is not reported but uncovered during the screening of the
application, the MAC shall follow previous established guidance to address the missing
information.
Section 4: Medical Specialty Information
This section captures the physician, eligible professional or other non-physician type specialty of
the provider. Please refer to the General Information section for a list of the providers who are
eligible to order and certify items and services to Medicare beneficiaries.
A – Physician Specialty
The provider shall select their primary specialty in this section. Only one specialty shall be
selected. The provider must meet all state requirements for the type of specialty checked. If a
physician specialty is not identified, the MAC shall send a development request to the
provider/contact person to obtain the missing data.
B – Eligible Professional or Other Non-Physician Type Specialty
The provider shall select their Eligible Professional or Other Non-Physician Type Specialty in
this section. Only one specialty shall be selected. Eligible Professional or Other Non-Physician
Type Specialty must meet specific licensing, certification, educational and work experience
requirements for the type of specialty selected. If a Eligible Professional or Other Non-
Physician Type Specialty is not identified, the MAC shall send a development request to the
provider/contact person to obtain the missing data.
Section 5: Important Address Information
The correspondence address must be one where the MAC can directly contact the applicant to
resolve any issues once the provider is enrolled in the Medicare program. It cannot be the
address of a billing agency, management services organization, chain home office, or the
provider’s representative (e.g., attorney, financial advisor). It can, however, be a P.O. Box or, in
the case of an individual practitioner, the person’s home address. The MAC may accept a
particular correspondence address if it has no reason to suspect that it does not belong to or is not
somehow associated with the provider. If a particular address lacks a city or state, the MAC can
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Instructions for CMS-855O Medicare Enrollment Application – Enrollment for Eligible Ordering, Certifying
and Prescribing Physicians, and Other Eligible Professionals
verify the missing data in any manner it chooses. In addition, the MAC can obtain the zip + four
from either the U.S. Postal Service or address validation functionality in PECOS.
The provider may list any telephone number it wishes as the correspondence phone number. The
number need not link to the listed correspondence address. The MAC may accept this telephone
number if it has no reason to suspect that it does not belong to or is not somehow associated with
the provider. If the provider fails to list a correspondence telephone number and it is required for
the application submission, the MAC shall develop for this information – preferably via email or
fax.
The provider may list an email address, however, email is not required. The email address listed
on the application can be a generic email address. It need not be that of a specific individual. The
MAC may accept a particular email address if it has no reason to suspect that it does not belong
to or is not somehow associated with the provider.
Section 6: Contact Person Information
This section captures information regarding the person who should be contacted regarding this
application. Multiple contact persons are allowed to be captured and the provider/contact person
may copy this page and include in the Form CMS-855O submission to the MAC. The MAC has
the discretion to use the contact persons listed in section 6 of the Form CMS-855O for all written
and oral communications (e.g., mail, email, telephone) related to the provider’s Medicare
enrollment. Such communication need not be restricted to a particular enrollment application of
the provider that the MAC is currently processing. Nor is the MAC required (again, unless either
CMS or the provider directs otherwise) to send certain materials to the correspondence mailing
or email address rather than the contact person’s mailing or email address. MACs shall validate
that the:
• Contact person provided his/her first name, middle initial, and last name with any
suffixes as well as the address, city/town, state, zip code, telephone and fax number
(optional).
• Contact person supplied an email address, although this is not required.
• Contact Person listed his or her relationship or affiliation to the individual practitioner or
clinic/group/organization, although this is not required.
• Communications regarding the processing of the Form CMS-855O shall be sent to the
contact person listed. If multiple contact persons are listed, the MAC shall contact the
first contact person listed on the application. If they are not available, the MAC shall
contact the other person(s) listed, unless the provider indicates otherwise via any means.
• If no contact person is listed in this section, the MAC shall contact the provider in
Section 2 or another contact person on file. The MAC need not develop for the
information in this section.
• If a contact person is listed, any other missing data (e.g., address, e-mail) can be captured
via telephone. This instruction applies only to Section 5.
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Instructions for CMS-855O Medicare Enrollment Application – Enrollment for Eligible Ordering, Certifying
and Prescribing Physicians, and Other Eligible Professionals
If this section is completely blank, the MAC need not develop for this information and can
simply contact the physician or practitioner.
Section 7: Penalties for Falsifying Information on this Application
This section explains the penalties for deliberately furnishing false information in this application
to gain or maintain enrollment in the Medicare program.
Section 8: Certification Statement and Signature
The provider is the only person who can sign this application. The authority to sign the
application on behalf of the provider may not be delegated to any other person. The certification
statement contains certain standards that must be met for initial and continuous enrollment in the
Medicare program solely to order and certify items and services for Medicare beneficiaries.
Note: Exceptions to the above policy may apply in the case of death, an executor of the estate,
may sign on behalf of the deceased provider.
All signatures must be original and signed in ink (blue ink preferred). Applications with
signatures deemed not original will not be processed. Stamped, faxed or copied signatures will
not be accepted.
A signed certification statement shall accompany the paper Form CMS-855O. If the provider
submits an invalid certification statement or fails to submit a certification statement, the MAC
shall still proceed with processing the application. An appropriate certification statement shall be
solicited as part of the development process. This includes certification statements that are: (a)
unsigned; (b) undated; (c) contains a copied or stamped signature; (d) was signed (as reflected
by the date of signature) more than 120 days prior to the date on which the MAC received the
application); (e) for paper Form CMS-855O submissions, someone other than the physician or
non-physician practitioner signed the form, except as noted above; or (f) missing certification
statements. The MAC shall send one development request to include a list of all of the missing
required data/documentation, including the certification statement. The MAC may reject the
provider’s application if the provider fails to furnish the missing information on the enrollment
application - including all necessary documentation - within 30 calendar days from the date the
MAC requested the missing information or documentation. Unless otherwise stated:
The certification statement may be returned via scanned email, fax or mail to the MAC
(as long as an original certification statement signature exist on file).
The MAC is not required to compare the signature thereon with the same provider’s
signature on file to ensure that it is the same person. The MAC shall not request the
submission of a driver’s license or passport to verify a signature.
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Instructions for CMS-855O Medicare Enrollment Application – Enrollment for Eligible Ordering, Certifying
and Prescribing Physicians, and Other Eligible Professionals
Note: Web-based application must be accompanied by an e-signature or web certification in
order for the MAC to begin processing the application.