Compliance CMS-855I
Validation Checks by Instafill.ai
1
Social Security Number Format and NPPES Consistency Validation
Validates that the Social Security Number (SSN) entered in Section 2A follows the standard 9-digit format (XXX-XX-XXXX) with no letters or special characters beyond hyphens. This check also verifies that the name and SSN provided match exactly what was used to obtain the applicant's NPI in NPPES, as CMS requires these to be identical in both PECOS and NPPES. If the SSN format is invalid or the name/SSN combination does not match NPPES records, the application will be rejected and enrollment delayed until corrected information is submitted.
2
National Provider Identifier (NPI) Type Consistency Validation
Ensures that a Type 1 (Individual) NPI is entered in Section 2A for the individual practitioner, and that a Type 2 (Organization) NPI is entered in Section 4A1 when a professional corporation, professional association, or LLC is reported. Mixing NPI types or entering an organization NPI in the individual practitioner field would cause a mismatch with NPPES records and prevent proper enrollment processing. If the wrong NPI type is submitted, the MAC will be unable to verify the provider's identity and the application will be returned or rejected.
3
Date of Birth Format and Reasonableness Validation
Validates that all Date of Birth fields (Section 2A for the individual practitioner, Section 6A for managing employees, and Section 8 for individual billing agents) are entered in the required mm/dd/yyyy format and represent a plausible date for a licensed medical professional. The date must not be in the future, must reflect an age consistent with having completed medical or professional training (generally at least 18 years old), and must match the applicant's Social Security Administration record. An invalid or implausible date of birth will cause a mismatch with SSA records and result in application rejection.
4
Reason for Submission Selection and Required Sections Completeness Check
Verifies that exactly one reason for submission is selected in Section 1A, and that all sections required for that specific reason are completed. For example, a voluntary termination submission must include an effective termination date and complete Sections 1A, 2A, 13 (optional), and 15, while a change of information submission must also complete Section 1B and all sections relevant to the specific change being reported. Failure to select a reason or to complete all required sections for the selected reason will result in the application being returned as incomplete, delaying enrollment or change processing.
5
Effective Date Format and Logical Validity for Change Actions
Validates that all effective dates provided for change, add, or remove actions throughout the form (Sections 2D, 2E, 4B, 4C, 4D, 4F, 6A, 8, and 13) are entered in the required mm/dd/yyyy format and represent a logically valid date. Effective dates for terminations must not precede the original enrollment date, and effective dates for new reassignments must not be in the past beyond a reasonable processing window. An improperly formatted or logically inconsistent effective date will prevent the MAC from processing the requested change and may result in payment disruptions.
6
License, Certification, and DEA Registration Active Status and Date Validation
Checks that all license numbers, certification numbers, and DEA registration numbers entered in Section 2B are accompanied by valid effective dates in mm/dd/yyyy format and that the issuing state is specified. If a compact license is indicated, the 'Yes' checkbox must be selected. The system verifies that at least one of the three subsections (Active License, Active Certification, or DEA Registration) is completed or marked 'Not Applicable,' and that the specialty reported in the license or certification aligns with the primary specialty selected in Section 2G or 2H. Missing or expired credentials will result in denial of enrollment or billing privileges.
7
Primary Specialty Single Selection and Separate Application Requirement Validation
Ensures that only one specialty is designated as Primary (P) in Section 2G for physicians or that only one specialty type is checked in Section 2H for non-physician practitioners, as the form explicitly prohibits multiple primary specialty designations on a single application. If a practitioner has multiple primary specialties or non-physician specialty types, a separate CMS-855I must be submitted for each. Selecting more than one primary specialty on a single application will cause the form to be rejected, and the practitioner must resubmit separate applications for each primary specialty.
8
Practice Location Address Physical Street Address Validation
Validates that all practice location addresses entered in Section 4B contain a physical street address as recorded by the United States Postal Service and do not contain a Post Office (P.O.) Box. Similarly, the Medicare Beneficiary Medical Records Storage Address in Section 4D must be a physical location and cannot be a P.O. Box or drop box. The correspondence mailing address in Section 2D may be a P.O. Box, but it cannot be a billing agent or medical management company address. Submitting a P.O. Box as a practice location or records storage address will result in the application being returned for correction.
9
Legal Business Name and TIN Consistency with IRS Records and NPPES Validation
Verifies that the Legal Business Name (LBN) and Tax Identification Number (TIN) entered in Section 4A1 for corporations, associations, or LLCs exactly match the name and TIN on IRS records (as confirmed by IRS Form CP-575 or equivalent) and also match the LBN and TIN used to obtain the organization's NPI in NPPES. The form instructions explicitly state that these must be identical in both PECOS and NPPES. Any discrepancy between the LBN/TIN on the application and IRS or NPPES records will result in rejection of the business entity enrollment and require resubmission with corrected documentation.
10
Final Adverse Legal Action Complete Reporting and Documentation Validation
Checks that Section 3C is fully completed whenever a 'Yes' response is given to the final adverse legal action question, including the specific action taken, the date it occurred, and the federal or state agency or court/administrative body that imposed the action. This same completeness requirement applies to the business entity adverse legal action history in Section 4A2 and the managing employee adverse legal action history in Section 6B. All applicable final adverse legal actions must be reported regardless of whether records were expunged or appeals are pending, and supporting documentation (notifications, resolutions, reinstatement letters) must be attached; incomplete reporting may constitute a material misrepresentation subject to criminal and civil penalties.
11
Reassignment of Benefits Dual Enrollment and Concurrent Application Validation
Validates that when a reassignment of benefits is being established in Section 4F, both the individual practitioner (Section 2A) and the receiving organization/group are currently enrolled in Medicare or are concurrently enrolling via a CMS-855B for the organization/group and a CMS-855I for the individual practitioner. The form requires that the organization/group's Legal Business Name match what was reported on their CMS-855B enrollment, and the individual's name must match their SSA record. If either party is not enrolled or concurrently enrolling, the reassignment cannot take effect and the application will be held pending enrollment of the unenrolled party.
12
Certification Statement Signature and Date Completeness Validation
Ensures that Section 15B contains both a handwritten signature and a date in mm/dd/yyyy format from the individual practitioner identified in Section 2A, as the form explicitly states that the authority to sign cannot be delegated to any other person. When a reassignment is being established or terminated, Section 15C must also be signed and dated by the delegated or authorized official of the receiving organization/group or individual. The printed name in Section 15B must match the name provided in Section 2A. An unsigned or undated certification statement will result in the application being returned unprocessed, as CMS cannot enroll a provider without a valid signed certification.
13
Business Structure Selection and Required IRS Documentation Consistency Validation
Verifies that the business structure selected in Section 4A (Proprietary, Non-Profit, or Disregarded Entity) is consistent with the required supporting documentation submitted with the application. Non-profit entities must submit IRS Form 501(c)(3), Disregarded Entities must submit IRS Form 8832, and sole proprietors using an EIN must submit IRS Form CP-575. If a business structure is selected but the corresponding IRS documentation is not included, or if the documentation submitted does not match the selected structure, the MAC will request the missing documents and the application will be delayed until all required documentation is received within the 30-day response window.
14
Electronic Funds Transfer (EFT) Authorization Agreement Submission Validation
Checks that a completed CMS-588 Electronic Funds Transfer Authorization Agreement accompanied by a voided check or bank letter is included with the application for all initial enrollments and reactivations where the practitioner is not reassigning 100% of their benefits to a group or organization. If the practitioner currently receives payments electronically and is not changing banking information, the CMS-588 is not required, but this exception must be verifiable against existing PECOS records. Additionally, if Medicare payments are directed to a bank where the practitioner has a lending relationship, a written waiver of the bank's right of offset must be provided; failure to include required EFT documentation will delay payment setup.
15
Billing Agency Address Cannot Match Correspondence Mailing Address Validation
Validates that the billing agency or agent address entered in Section 8 is not the same as the correspondence mailing address provided in Section 2D, as the form explicitly prohibits this. This check also ensures that the correspondence mailing address in Section 2D is not a billing agent, billing agency, or medical management company address. If the billing agency address matches the correspondence address, or if the correspondence address is identified as belonging to a billing entity, the application will be flagged for correction to ensure that MAC communications reach the provider directly rather than being intercepted by a third-party billing entity.
16
Specialty-Specific Subsection Completion Consistency Validation
Ensures that practitioners who select certain specialty types in Section 2H complete the corresponding specialty-specific subsections: Clinical Psychologists and Psychologists Billing Independently must complete Section 2I; Physical Therapists and Occupational Therapists in Private Practice must complete Section 2J; and Clinical Nurse Specialists and Nurse Practitioners must complete Section 2K. For psychologists billing independently, all four questions (2I2a through 2I2d) must be answered, and if the practice is located in an institution, the follow-up questions must also be completed. Failure to complete the required specialty-specific subsection will result in the application being returned as incomplete, as these sections contain eligibility-determining information specific to each specialty type.