Compliance CMS-855S
Validation Checks by Instafill.ai
1
National Provider Identifier (NPI) Format and Consistency Validation
Validates that the NPI entered in Section 2B is a valid 10-digit numeric identifier issued by NPPES, and cross-checks that the Legal Business Name (LBN) and Tax Identification Number (TIN) associated with the NPI in NPPES exactly match what is reported in Sections 2B and 4A of the application. This check is critical because CMS requires an exact match between PECOS and NPPES records before enrollment can proceed. If the NPI is missing, improperly formatted, or the associated name and TIN do not match, the application will be rejected or significantly delayed.
2
Legal Business Name and TIN Match Against IRS Records
Verifies that the Legal Business Name (LBN) provided in Section 4A exactly matches the name associated with the Tax Identification Number (TIN) as reported to the IRS, consistent with the IRS Form CP-575 or equivalent document that must be submitted with the application. Discrepancies between the LBN and TIN can result in incorrect 1099 reporting and payment processing errors. If this validation fails, the application cannot be processed and the supplier risks denial of Medicare billing privileges.
3
Date Format Validation for All Date Fields
Ensures that all date fields throughout the application — including business start date, insurance policy dates, accreditation effective and expiration dates, surety bond dates, ownership acquisition dates, and signature dates — are entered in the required mm/dd/yyyy format and represent valid calendar dates. Invalid or ambiguous date formats can cause processing errors and delays in the enrollment system. Fields with dates that are logically impossible (e.g., a termination date before a start date, or an expiration date before an effective date) must also be flagged as errors.
4
Authorized Official Signature Age Validation
Checks that the date signed by each Authorized Official and Delegated Official in Section 15 is not more than 120 days old at the time the application is submitted to the contractor, as explicitly required by the form instructions. Signatures older than 120 days are considered invalid and will result in the application being rejected and returned for re-signature. This validation must also confirm that the signature date is not a future date, which would indicate an error or potential fraud.
5
Minimum Weekly Hours of Operation Compliance Check
Validates that the total hours open to the public per week entered in Section 2A2 meets the minimum requirement of 30 hours per week as mandated by 42 C.F.R. section 424.57(c)(30), unless the supplier qualifies for the 'By Appointment Only' exception applicable to certain physician, therapist, or custom orthotics/prosthetics suppliers. The system should sum the daily hours entered for each day of the week and compare the total against the 30-hour threshold. Failure to meet this requirement is a direct violation of DMEPOS supplier standards and will result in denial or revocation of billing privileges.
6
Comprehensive Liability Insurance Minimum Coverage Amount Validation
Verifies that the comprehensive liability insurance policy reported in Section 7A provides coverage of at least $300,000 per incident, as required by 42 C.F.R. section 424.57(c)(10), and that the policy expiration date has not passed at the time of submission. The validation must also confirm that the contractor's full mailing address is listed as a certificate holder on the policy, and that a copy of the certificate of liability insurance is included with the application. If the coverage amount is below the required threshold or the policy has lapsed, the application will be denied and existing billing privileges may be revoked retroactively.
7
Social Security Number (SSN) Format Validation for Individuals
Validates that all SSNs entered for individuals in Sections 4A (Sole Proprietors), 6A (Individual Ownership/Managing Control), and Section 15 (Authorized and Delegated Officials) conform to the standard 9-digit SSN format (XXX-XX-XXXX) and do not contain invalid sequences such as all zeros, repeated digits, or known test numbers. The form explicitly states that the name, date of birth, and SSN of each person must coincide with information on file with the Social Security Administration. An invalid or mismatched SSN will prevent identity verification and result in application rejection.
8
Tax Identification Number (TIN) Format Validation
Ensures that the TIN provided in Sections 2B, 4A, 5A, and 7B (Surety Bond Company) is a valid 9-digit Employer Identification Number (EIN) in the format XX-XXXXXXX for organizational suppliers, or a valid 9-digit SSN for sole proprietors who have not provided an EIN. The validation must also confirm that sole proprietors do not enter both an SSN and an EIN simultaneously, as the form explicitly states only one number may be used to bill Medicare. An improperly formatted or missing TIN will prevent IRS matching and result in processing delays or denial.
9
Business Location Address Street Address Completeness and P.O. Box Prohibition
Validates that the Business Location Address in Section 2A1 contains a specific street address as recorded by the United States Postal Service, and that a P.O. Box has not been entered as the primary business location address. The form explicitly prohibits P.O. Boxes for the business location, as the address must represent a physical facility accessible to the public. Similarly, the Medical Records Storage Address in Section 4E must not be a P.O. Box or drop box. Failure to provide a valid physical street address will result in application rejection, as site visits cannot be conducted at a P.O. Box.
10
Accreditation Information Completeness and Expiration Date Validation
Checks that suppliers who are not exempt from the accreditation requirement have provided the name of a CMS-approved accrediting organization along with both the effective date and expiration date of current accreditation in Section 2E2, and that the accreditation has not expired at the time of submission. The accreditation must cover the specific products and services for which the supplier is seeking billing privileges, as listed in Section 2E4. An expired or missing accreditation will result in denial of enrollment or revocation of billing privileges for the affected products and services.
11
Final Adverse Legal Action Disclosure Completeness Validation
Verifies that Section 3C is fully completed when a 'Yes' response is given to the question about prior final adverse legal actions, requiring that each action is documented with 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 check applies to Sections 5B and 6B for owning/managing organizations and individuals, respectively. Incomplete disclosure of adverse legal actions — including those that were expunged or are under appeal — constitutes a material omission that can result in criminal and civil penalties under 18 U.S.C. section 1001 and exclusion from the Medicare program.
12
Reason for Submission Selection and Required Sections Consistency Check
Validates that exactly one reason for submission has been selected in Section 1A, and that all sections required for that specific submission type have been completed. For example, a new enrollee must complete all sections, while a supplier adding a new location using an existing TIN only needs to complete Sections 1–4, 6 (managing employee only), 12, 13, and 15. If a voluntary termination is selected, the effective termination date must be provided and must be a valid future or current date. Submitting an incomplete set of required sections based on the submission type will result in processing delays or rejection of the application.
13
Ownership and Managing Control Minimum Reporting Requirements Validation
Confirms that the application includes at least one organizational or individual owner reported in Sections 5 or 6, at least one managing employee reported in Section 6, and at least one Authorized Official reported in Section 15, as explicitly required by the form instructions. For corporate suppliers, all officers and directors must be reported in Section 6. If any of these minimum reporting requirements are not met, the application is incomplete and cannot be processed, as CMS requires full disclosure of all ownership and control relationships to assess program integrity risks.
14
Correspondence Address Restriction Validation
Validates that the Correspondence Mailing Address in Section 4B1, the Medical Record Correspondence Address in Section 4B2, and the Revalidation Request Package Mailing Address in Section 4C are not the address of a billing agency, Management Services Organization, or the supplier's representative, as explicitly prohibited by the form instructions. These addresses must be directly associated with the supplier to ensure that official communications reach the responsible party. If a prohibited address type is detected, the application must be flagged for correction to prevent misdirection of sensitive enrollment correspondence.
15
Primary Supplier Type Single Selection Validation
Ensures that exactly one supplier type is designated as 'Primary' (P) in Section 2E1, as the form explicitly states that only one primary supplier type may be selected per business location. Multiple secondary supplier types (S) are permitted and should be validated to confirm they are drawn from the approved list of eligible DMEPOS supplier types. If no primary supplier type is selected, or if more than one is marked as primary, the application cannot be processed, as the primary supplier type determines the applicable Medicare requirements and licensure standards that must be met.
16
Surety Bond Amount and Required Documentation Validation
Verifies that suppliers required to obtain a surety bond under 42 C.F.R. section 424.57(d) have completed Section 7B with the surety bond company's legal business name, TIN, address, bond amount, bond number, and effective date, and that a copy of the original surety bond signed by a Delegated or Authorized Official is included with the application. If the supplier claims an exemption from the surety bond requirement in Section 7C, the applicable exemption criterion must be selected and must be consistent with the supplier type reported in Section 2E1. Missing or inconsistent surety bond information will result in application denial for suppliers who do not qualify for an exemption.