Compliance CMS-855A
Validation Checks by Instafill.ai
1
Legal Business Name Matches IRS Records and NPI Registration
The Legal Business Name (LBN) entered in Section 2B1 must exactly match the name on file with the IRS (as confirmed by IRS CP 575 or equivalent documentation) and must also match the name used to obtain the National Provider Identifier (NPI) in NPPES. Even minor discrepancies such as abbreviations, punctuation differences, or missing words will cause a mismatch between PECOS and NPPES. If this validation fails, the application will be delayed or rejected, as CMS requires the LBN, TIN, and NPI to match exactly across both systems.
2
Tax Identification Number (TIN) Format and Consistency
The Tax Identification Number must be a valid 9-digit Employer Identification Number (EIN) in the format XX-XXXXXXX, as institutional providers enrolling on the CMS-855A are organizational entities and should not be using a Social Security Number as their primary TIN. The TIN entered in Section 2B1 must be consistent with the TIN used to obtain the NPI and must match IRS records. If the TIN does not match IRS documentation or conflicts with the NPI registration, the enrollment will be rejected and the provider will be unable to receive Medicare payments.
3
National Provider Identifier (NPI) Validity and Entity Type
The NPI provided must be a valid Type 2 (Entity/Organization) NPI, as all institutional providers submitting the CMS-855A are required to hold an Entity Type 2 NPI. The NPI must be active and registered in NPPES prior to submission of the enrollment application, with the exception of Organ Procurement Organizations which are exempt from the NPI requirement. If the NPI is a Type 1 (individual) NPI, is inactive, or has not yet been issued, the application cannot be processed and enrollment will be denied until a valid Type 2 NPI is obtained.
4
Date Format Validation for All Date Fields
All date fields throughout the application, including effective dates, dates of birth, license effective dates, accreditation dates, termination dates, and the date of first Medicare patient, must be entered in the required mm/dd/yyyy format. Dates must represent valid calendar dates (e.g., month values between 01–12, day values appropriate for the given month, and a four-digit year). Invalid or improperly formatted dates will prevent the MAC from processing the application and may result in incorrect effective dates for enrollment, ownership changes, or terminations.
5
Reason for Submission Selection and Required Sections Completeness
Exactly one reason for submission must be selected in Section 1A, and all sections required for that specific reason must be completed. For example, a new enrollee must complete all applicable sections except 2G, 2H, and 2I, while a CHOW buyer must complete all sections except 2H and 2I. If the reason for submission is not selected, or if required sections for the selected reason are left incomplete, the MAC will be unable to process the application and will return it to the provider, causing significant enrollment delays.
6
Practice Location Address Cannot Be a P.O. Box
All practice location addresses entered in Section 4A must be physical street addresses as recorded by the United States Postal Service and cannot be Post Office (P.O.) Box addresses. Similarly, medical records storage addresses in Section 4C cannot be P.O. Boxes or drop boxes. This requirement ensures that CMS and the MAC can verify the physical location where services are rendered to Medicare beneficiaries. If a P.O. Box is entered as a practice location address, the application will be rejected and the provider will be required to resubmit with a valid physical address.
7
Social Security Number Format for Individuals in Sections 5C, 6, 10, and 15
All Social Security Numbers (SSNs) entered for individuals throughout the application, including chain home office administrators (Section 5C), individual owners and managing employees (Section 6), OTP personnel (Section 10), and authorized/delegated officials (Section 15), must be in the standard 9-digit format (XXX-XX-XXXX). The form explicitly states that each authorized and delegated official must have and disclose their SSN. Missing or improperly formatted SSNs will prevent identity verification and background checks, and may result in the application being returned or denied.
8
Direct Ownership Percentage Totals Do Not Exceed 100%
The combined percentage totals for all direct owners reported in Section 5 (organizations) and Section 6 (individuals) must not exceed 100%. Each ownership entry requires an exact percentage, and the system must validate that the sum of all direct ownership interests does not surpass 100% of the provider's total ownership. Exceeding 100% in direct ownership percentages indicates a data entry error or misreporting of ownership structure, which could trigger fraud and abuse scrutiny and result in application denial or revocation of billing privileges.
9
Authorized Official Signature and Date Present on Section 15
Section 15B must contain a valid signature and date from at least one authorized official, as the application explicitly states it must be signed and dated in order to be processed. The authorized official must be an appointed individual such as a CEO, CFO, general partner, or chairman of the board who has been granted legal authority to enroll the organization in Medicare. If the signature is missing, the date is absent, or the signer does not qualify as an authorized official as defined in Section 15, the application will be rejected outright and cannot be processed by the MAC.
10
Final Adverse Legal Action Disclosure Completeness
Section 3 must be completed in its entirety for the provider organization, and Sections 5D and 6B must be completed for each reported organization and individual respectively, disclosing all final adverse legal actions including convictions, exclusions, license revocations, and suspensions within the preceding 10 years. All applicable supporting documentation (notifications, resolutions, reinstatement letters) must be attached. Incomplete disclosure of adverse legal actions, even those that were expunged or are under appeal, constitutes a material omission that can result in denial of enrollment, revocation of billing privileges, and potential criminal or civil penalties under 18 U.S.C. section 1001.
11
Provider Type Selection Consistency with Application Type
Only one provider type may be selected in Section 2A1 (or 2A2 for hospitals), and the selected provider type must be one of the recognized institutional provider types listed on the CMS-855A. If a provider functions as two or more separately recognized provider types (e.g., both a hospital and an ESRD facility), a separate CMS-855A must be submitted for each type rather than selecting multiple types on a single application. Selecting an incorrect or unsupported provider type, or attempting to enroll multiple distinct provider types on one application, will result in processing errors and potential denial of enrollment.
12
Accreditation Date Logical Consistency
If the provider indicates it is accredited in Section 2E, both the date of accreditation and the expiration date of accreditation must be provided, and the expiration date must be a future date that is chronologically after the accreditation date. An expiration date that precedes the accreditation date, or an accreditation that has already expired at the time of submission, indicates either a data entry error or lapsed accreditation status. Submitting an application with expired accreditation may result in the MAC requiring updated accreditation documentation before enrollment can be approved.
13
Billing Agency Address Cannot Match Correspondence Mailing Address
If a billing agency or agent is reported in Section 8, the billing agency's address must be different from the provider's correspondence mailing address entered in Section 2C. The form explicitly prohibits the use of a billing agent or agency's address as the provider's correspondence mailing address, ensuring that official MAC communications are directed to the provider rather than a third-party billing entity. If the billing agency address matches the correspondence address, the application must be corrected before submission to ensure the provider receives all enrollment-related correspondence directly.
14
OTP Personnel NPI and License Number Validity
For Opioid Treatment Programs completing Section 10, all ordering and dispensing personnel must have an active and valid NPI and a current license number provided. The NPI must be a Type 1 (individual) NPI for each practitioner listed, and the license must be active at the time of application submission. OTP personnel who are currently revoked from Medicare, on the CMS preclusion list, excluded by OIG, or have prior state board actions for patient harm-related misconduct cannot be employed or contracted by the OTP. Failure to report complete and valid NPI and license information for all OTP personnel will result in application rejection and potential compliance violations under 42 C.F.R. section 424.67.
15
Home Health Agency Capitalization Documentation Completeness
Home Health Agencies initially enrolling in Medicare on or after January 1, 1998 must complete Section 12 and provide documentation of sufficient initial reserve operating funds, including a financial statement, a bank attestation confirming fund availability, and a certification that at least 50% of reserve funds are non-borrowed. The projected number of visits for the first three months and first twelve months of operation must also be provided to allow the MAC to compare the enrolling HHA with comparable agencies. Failure to provide complete capitalization documentation will prevent the MAC from verifying financial readiness and will delay or deny the granting of Medicare billing privileges to the HHA.
16
CHOW Effective Date and Provider Agreement Assignment Consistency
For Change of Ownership submissions in Section 2G, the effective date of transfer must be provided and can be a future date, but must be a valid calendar date in mm/dd/yyyy format. The new owner must indicate whether they will accept assignment of the current provider agreement; if they elect not to accept the transfer, the old agreement must be terminated and the new owner is treated as an initial enrollee, requiring completion of all applicable new enrollment sections. A copy of the bill of sale must be submitted with the application, and the final sales agreement must be submitted once executed. Inconsistency between the CHOW election and the sections completed (e.g., selecting buyer/new owner but not completing all required sections) will result in application rejection.