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Form 855 may be simplified
Responding to physician complaints, Health Care Financing Administration (HCFA) officials say they plan to revise HCFA Form 855 (the Medicare Health Care Provider/Supplier Appli cation Form) and enrollment regulation.
All Medicare providers, including physicians, hospitals, and durable medical equipment suppliers must complete Form 855 to receive a Medicare provider number under which to bill the program.
Look for the proposed changes to be unveiled in the fall, with the revisions targeted to take effect early next year, says Penny Thompson, HCFA’s director of the Program Integrity Group.
The new form and accompanying proposed regulations will codify which providers are eligible for — and who may be excluded from — the Medicare program, and on what basis HCFA could make these decisions, notes Pat Smith of the Medical Group Management Association’s (MGMA) Washington, DC, office
"MGMA met with HCFA officials in early May to express our concerns with Form 855," says Smith. "It appears HCFA has responded to our concerns, such as the complexity of the form and improving processing procedures."
Providers have asked HCFA to correct the following key problem areas with the form:
• Make the form simpler and easier to understand. HCFA has indicated it intends to alter the instruction section of the form so each section of instructions is located with the appropriate section of the form, say MGMA officials. HCFA also may rewrite portions of the instructions and include a matrix that explains which enrollees should fill out which sections of the form.
• Reduce the amount of requested information. HCFA’s Thompson says the agency will try to reduce the amount of information it asks for, while also incorporating such innovations as "check-off" boxes that permit enrollees to avoid having to provide duplicate information.
• Eliminate or revise "contractor information" sections. HCFA is re-examining this section to determine what data it really needs.
• Facilitate electronic filing. To make filing easier, HCFA is considering placing the form on the Internet. The agency also may use the Internet to list who is excluded from the Medicare program, enabling providers to know which individuals and organizations they should not be contracting with.
• Simplify the renewal process. Rather than having to completely fill out the form when it is time to renew an application, HCFA is considering ways providers can simply revise and update already filed information.
MGMA says HCFA is considering having providers complete or update their Form 855 every three years or so, while submitting any "material" changes within 30 days of the change. However, HCFA still is not sure how to define what constitutes a "material" change.
Criteria for determining eligibility
HCFA’s expected proposed rule revising Form 855 for deciding a provider’s Medicare eligibility will be based on a set of specific criteria. Under HCFA’s most recent draft, a provider would be excluded from Medicare if the provider has:
— committed a felony within the last five years;
— been excluded from participation in a federal program;
— failed to disclose information that would otherwise make the provider ineligible;
— failed to submit required cost reports;
— failed to meet requirements for provider type;
— stopped business activities as evidenced by a lack of claims submission for one year.
Additionally, HCFA would have the option to exclude providers if they:
— committed a felony more than five years ago;
— provided any false or misleading information on HCFA Form 855;
— are under indictment for felonies that would serve as the basis for denial or exclusion;
— are under payment suspension associated with another provider;
— previously left the program with outstanding debts;
— have a history of high error rates in claims submissions;
— have not been able to obtain or have lost licensure;
— failed on-site visits due to unqualified technicians conducting tests, required physician supervision not being present, or other reasons such as personnel working outside the scope of their licensure or supporting conditions that may harm beneficiaries;
— failed to provide records needed for payment or for establishing Medicare eligibility.