Compliance CMS-20134
Validation Checks by Instafill.ai
1
Legal Business Name Matches IRS Tax Documentation
Validates that the Legal Business Name entered in Section 2B1 exactly matches the name on file with the IRS as confirmed by the submitted IRS confirmation document (e.g., IRS Form CP 575). This check is critical because discrepancies between the application name and IRS records can cause payment delays or denials. If the names do not match, the application will be flagged for correction before processing can continue, as the MAC uses this information to verify the supplier's tax identity.
2
Tax Identification Number Format Validation
Ensures the Tax Identification Number (TIN) entered in Section 2B1 conforms to the standard IRS format of nine digits, typically formatted as XX-XXXXXXX for Employer Identification Numbers (EINs) or XXX-XX-XXXX for Social Security Numbers used by sole proprietors. An incorrectly formatted or incomplete TIN will prevent the MAC from verifying the supplier's identity with the IRS. Failure to provide a valid TIN will result in the application being returned or delayed.
3
National Provider Identifier (NPI) Format and Type Validation
Validates that all NPIs entered throughout the application are exactly 10 digits in length and conform to the Luhn algorithm check digit standard as assigned by NPPES. Additionally, this check verifies that the correct NPI type is used: Type 1 (individual) for sole proprietors and Type 2 (organizational) for corporations, partnerships, and LLCs, as specified in the billing number information section. Submitting an incorrect NPI type or a malformed NPI number will result in enrollment denial or processing delays, as the NPI must be obtained and validated before the application is submitted.
4
Supplier Type Selection Completeness
Confirms that exactly one supplier type has been selected in Section 2A from the three available options: In-Person MDPP Supplier, In-Person with Distance Learning MDPP Supplier, or Online MDPP Supplier. The form instructions specify that if a supplier operates as more than one type, a separate application must be submitted for each type. If no supplier type is selected or multiple types are checked on a single application, the application is considered incomplete and will not be processed.
5
Reason for Application Selection and Required Sections Completion
Verifies that exactly one reason for application has been selected in Section 1A (new enrollee, reactivation, voluntary termination, change of information, or revalidation) and that all required sections corresponding to that reason have been completed as specified in the Section 1A table. For example, a voluntary termination requires an Effective Date of Termination and completion of Sections 1, 2B1, 13, and either 15 or 16. Incomplete section coverage based on the selected reason will result in the application being returned for correction.
6
Date Format Consistency Across All Date Fields
Validates that all date fields throughout the application (including Incorporation Date, Recognition Status Effective Date, Expiration/Renewal Date, coach start/end dates, ownership acquisition dates, and signature dates) are entered in the required mm/dd/yyyy format. Dates entered in any other format (e.g., mm/yyyy, yyyy-mm-dd, or written out) will be flagged as invalid. Incorrectly formatted dates can cause processing errors and may result in incorrect effective dates being applied to enrollment records.
7
Administrative Location Address Cannot Be a P.O. Box
Checks that the street addresses provided in Section 4A for administrative locations and community settings are physical street addresses and do not contain P.O. Box entries. The form explicitly states that a P.O. Box is not acceptable for location addresses, as the MAC must be able to conduct site visits to verify compliance with supplier standards under 42 C.F.R. § 424.205(d). Similarly, medical record storage addresses in Section 4C must also be physical addresses, not P.O. boxes or drop boxes.
8
Correspondence Address Cannot Be a Billing Agency Address
Validates that the correspondence address provided in Section 2B3 is the supplier's own address and not the address of any billing agency listed in Section 8. The form explicitly prohibits using a billing agency's address as the correspondence address, as the MAC needs to be able to contact the supplier directly for enrollment-related communications. If the correspondence address matches the billing agency address entered in Section 8, the application must be corrected before submission.
9
Social Security Number Format Validation for Individuals
Ensures that all Social Security Numbers (SSNs) entered for individuals in Section 6A (owners, officers, directors, managing employees) and Section 7 (coaches) conform to the standard nine-digit format XXX-XX-XXXX. The form states that the name, date of birth, and SSN of each person listed must match the information on file with the Social Security Administration. An improperly formatted or missing SSN will prevent identity verification and result in the application being returned, as SSNs are required for all authorized and delegated officials.
10
Coach Required Fields Completeness Validation
Verifies that all required fields for each coach listed in Section 7 are fully completed, including First Name, Last Name, Social Security Number, Date of Birth, and NPI. The form marks all five of these fields as required for each coach entry. Missing any of these fields for a coach will prevent the MAC from verifying coach eligibility against exclusion databases, which is a mandatory step in the enrollment review process under 42 C.F.R. § 424.205(d)(3) and (e).
11
Final Adverse Legal Action Disclosure Completeness
Validates that Section 3 is answered completely for the organization, and that Sections 5B and 6B are answered for each owning/managing organization and individual respectively. If the answer to the adverse legal action question is 'Yes,' the validation checks that the subsequent detail fields (action type, date, action taken by, and resolution) are all populated and that supporting documentation is attached. Incomplete disclosure of adverse legal actions, even those that were expunged or are under appeal, constitutes a material omission that can result in enrollment denial or revocation.
12
Authorized Official Signature and Title Validation
Confirms that Section 15 contains at least one authorized official's complete information including First Name, Last Name, Title/Position, Telephone Number, and a dated original signature. The title must correspond to an eligible authorized official role such as CEO, CFO, general partner, chairman of the board, or direct owner. The signature date must not be prior to the application completion date. Applications signed by delegated officials for initial enrollment or revalidation will be rejected, as only authorized officials have the authority to sign these application types.
13
Delegated Official Employment Status and Authorization Validation
When a delegated official is listed in Section 16, validates that the W-2 Employee checkbox is appropriately marked or that the individual has an ownership or control interest in the supplier, since independent contractors are explicitly prohibited from serving as delegated officials. Additionally, checks that the authorized official's countersignature assigning the delegation is present and dated in Section 16. A delegated official who does not meet the eligibility criteria or whose delegation is not properly authorized by an authorized official's signature cannot legally bind the supplier.
14
Recognition Status Organizational Code and Expiration Date Presence
Validates that the Recognition Status section (Section 2B2) contains a valid CDC Organizational Code, an Effective Date, and an Expiration/Renewal Date, and that at least one of the three MDPP delivery type checkboxes (In-person, In-person with Distance Learning, or Online) is marked 'Yes' to correspond with the supplier type selected in Section 2A. The recognition status must be current and not expired, as maintaining MDPP preliminary or full CDC DPRP recognition is a mandatory supplier standard under 42 C.F.R. § 424.205(d)(1). An expired or missing recognition status will result in enrollment denial.
15
Ownership Interest Threshold and Organization vs. Individual Section Routing
Validates that all entities with 5 percent or more ownership interest, managing control, or partnership interest are reported in the correct section: organizations in Section 5 and individuals in Section 6. The check also verifies that for corporations, all officers and directors are listed in Section 6 regardless of ownership percentage, and that all partners in a partnership are listed regardless of their ownership percentage falling below the 5 percent threshold. Misrouting an organization to Section 6 or an individual to Section 5, or omitting required owners, constitutes an incomplete application and may trigger additional scrutiny or denial.
16
Supporting Documentation Checklist Completeness
Verifies that all mandatory supporting documents listed in Section 17 are indicated as attached, including the CDC MDPP Recognition Certificate or Determination Letter, IRS written confirmation of TIN matching the Legal Business Name, and a completed CMS-588 Electronic Funds Transfer Authorization form (unless the supplier already receives EFT payments with no banking changes). Conditional documents such as the IRS non-profit determination letter, Form 8832 for disregarded entities, and adverse action documentation must also be included when applicable. Submitting the application without required supporting documentation is one of the most common causes of enrollment delays and will result in the MAC requesting the missing items within a 30-day response window.