In May 2006, CMS issued revised enrollment applications with several changes that affect the way you handle the all-important NSC reenrollment.
The National Supplier Clearing-house (NSC) is required by CMS and 42 CFR section 424.57(e) to reenroll DMEPOS suppliers every 3 years. The NSC, acting for CMS, is the central entity responsible for maintaining supplier identification and ownership data, as well as other business data. Part of that responsibility includes sharing this information with other DME Contractors. DME Contractors use this information for provider relations and claims processing.
Therefore, it is imperative the NSC have the most accurate information on file. Further, the reenrollment process also allows the NSC to determine if the supplier is in compliance with the 21 DMEPOS supplier standards found at 42 CFR 424.57(c). On May 1, 2006, CMS issued the revised CMS 855 Medi-care enrollment applications. Listed below are changes and enhancements made specifically to the CMS 855S. DMEPOS suppliers should review and become familiar with this information.
The CMS 855S (04/06):
• Requires the submission of the National Provider Identifier (NPI) and a copy of the NPI notification furnished by the National Plan and Provider Enumeration System (NPPES). Suppliers should provide their NPI where required and submit a copy of the notification verifying the NPI. If you are unable to locate your NPI notification, you may contact the NPPES at (800) 465-3203 or send an e-mail to customerservice@npienumerator.com.
• Suggests that suppliers should list their NPI on any enrollment documentation submitted, but are required to submit a copy of the notification only once. If the NPI information is not submitted, the NSC analyst will have to develop the information, which will delay processing.
• Added a section for suppliers to provide a specific address where the NSC should mail their reenrollment packages. If a supplier would like to receive their reenrollment at an address other than the address where correspondence is received, the supplier should list this address in section 2.A.3. This enhancement was made to provide all suppliers, especially those suppliers with multiple locations, with a single address where they can receive their reenrollment packages.
• Requires all new suppliers to complete the Authorization Agreement for Electronic Funds Transfer (CMS 588), and reenrolling suppliers should submit the CMS 588 form if they are not already enrolled to receive payments electronically.
• Says that suppliers must complete a separate form for each Medicare contractor where it submits claims. The form must list the proper Medicare contractor and the supplier’s legal business name, and have the original signature of an authorized or delegated official. Also, suppliers must include with each form a voided check, preprinted deposit slip, or confirmation of account information on bank letterhead for verification of the account number.
• Defines the NSC’s role to simply verify that the form has been completed and signed ap-propriately. Once verified, the NSC will send the agreements to the appropriate DME Con-tractor for processing.
• Requires suppliers to provide the name and phone number of the insurance underwriter. The NSC is required by CMS to contact the insurance underwriter to verify coverage and not the insurance agent. Section 2.D requires suppliers to provide identifying information for both the insurance agent and the underwriter. Providing this information will assist in facilitating the verification process.
• Added a section for suppliers to provide information concerning accreditation. CMS has tasked the NSC with collecting and storing this information. However, CMS has yet to issue a final rule regarding accreditation. Therefore, suppliers who do not have an accreditation may check “The enrolling supplier is not accredited” and move on to the next section. However, if a supplier is accredited, this information must be reported.
• Provides suppliers with the option to appoint multiple authorized and delegated officials. Sections 15 and 16 allow suppliers to add as many authorized and delegated officials as desired. However, each individual is still required to be listed in section 6 and must meet the respective definition of an authorized or delegated official.
Per CMS instructions, the NSC will continue to use the CMS 855S (11/01) application when mailing the preprinted reenrollment form to suppliers. Sections 3, 14, and 15 of the 11/01 version will be replaced with the respective sections from the revised CMS 855S. Instructions for submitting NPI and EFT documentation will be contained in the reenrollment cover letter.
These changes and enhancements were made to ensure CMS obtains the necessary information to enroll only qualified entities into the Medicare program while at the same time reducing the burden on the supplier community.
Below are answers to frequently asked questions, helpful hints, and resources to assist with completing the reenrollment process. This information is also available on the NSC Web site, www.palmettogba.com/nsc, under Supplier Enrollment/FAQs/Reenrollment. Additional information regarding the reenrollment process may be found under Supplier Enrollment/Reenrollment.
How are suppliers chosen to reenroll? Every month the NSC chooses one twelfth of the supplier population required to reenroll during that calendar year. Depending on the workload or the number of suppliers scheduled to reenroll, some suppliers may receive their reenrollment packages a month or two earlier or later than the anniversary date of either the issuance of their supplier number or the date of the last reenrollment. In any case, the supplier will receive a reenrollment package sometime during the anniversary year.
Once received, how long do I have to submit the reenrollment? As stated in the letter that accompanies the reenrollment packages, the supplier has 35 days from the date on the reenrollment letter to submit the completed CMS 855S along with all required documentation. If the information is not received in a timely manner, the supplier is subject to inactivation of its supplier number.
If a supplier is unable to submit the reenrollment within the 35 days, the NSC may issue the supplier a one-time extension of 60 days. The 60-day extension begins the date requested and not after the 35-day requirement. Suppliers may request the extension by contacting the NSC Customer Service Line at (866) 238-9652 or e-mailing the request to medicare.nsc@palmettogba.com.
What documentation should be submitted with the reenrollment? The documentation required by CMS to be submitted with the reenrollment package depends on the specialty and/or number of active supplier numbers a supplier has under an existing tax identification number (TIN). The chart on page 99 indicates what documentation must be submitted. All suppliers are required to list their NPI, and if they have not previously submitted a copy of the NPI notification from the NPI enumerator, they should do so with the reenrollment. Also, a reenrolling supplier not already enrolled to receive payments electronically, should submit the Authorization Agreement for Electronic Funds Transfer (CMS 588), completed appropriately, and submitted with the required documentation verifying the bank account number.
If a supplier is removing an individual from the supplier file, no additional documentation is required to be submitted for the individual being removed. For example, if a supplier is removing a board member, the NSC will not require additional documentation such as board minutes to remove the individual. As long as Section 6 is completed correctly to delete the individual and the CMS 855S is signed properly, the individual will be removed from the file.
What information must be included on the insurance documentation? The following information must be listed on the insurance policy: 1. NSC as the Certificate Holder 2. Legal business name 3. Policy number 4. Issue and expiration dates 5. Physical locations covered 6. Policy indicates at least $300,000 in comprehensive liability coverage
As previously stated, the revised CMS 855S requires suppliers to provide the name and phone number of the insurance underwriter. The NSC is required by CMS to contact the insurance underwriter to verify coverage and not the insurance agent. Please be sure to list the required contact information in Section 2.D. Providing this information will assist in facilitating the verification process.
Suppliers should also keep in mind that supplier standard #10 requires suppliers to have comprehensive liability coverage in the amount of at least $300,000. The insurance policy must remain in force at all times and provide the required coverage per incident. Failure to maintain the required insurance at all times will result in the revocation of the supplier number, retroactive to the date the insurance lapsed.
The NSC offers a variety of tools to assist the supplier community with completing the reenrollment process, as well as assisting with all areas of enrollment. These tools include:
1. Helpful hints for completing the CMS 855S 2. Numerous FAQs regarding the enrollment process 3. “The NSC Top Ten”—the top 10 reoccurring issues that delay processing 4. Information regarding the NSC site visit process 5. Licensure information 6. A checklist to ensure that the CMS 855S was completed prop-erly and that all required documentation has been provided
The NSC Customer Service Line (866-238-9652) NSC analysts are available Monday through Friday from 9:00 am until 5:00 pm (EST) to answer questions regarding the enrollment process. If you have questions regarding supplier-specific information, be sure an individual listed on the supplier file contacts the NSC Customer Service Line. NSC analysts will not be able to give supplier-specific information to someone who is not listed on the supplier file. Spanish-speaking suppliers, who cannot speak English, may leave a voicemail and a Spanish-speaking analyst will return the call.
NSC e-mail address If preferred, suppliers can e-mail their questions to medicare.nsc@palmettogba.com. Questions received will be answered in a reasonable time frame. The NSC suggests suppliers do not submit protected health care information via e-mail.
Interactive Voice Response (IVR) Unit The NSC Interactive Voice Response (IVR) Unit allows suppliers to obtain:
1. General information regarding the enrollment process 2. Information on the appeals process 3. Status of a new application, reenrollment, reactivation, or change of information 4. Instructions on how to obtain a CMS 855S 5. Contact information for the NSC, DMERCs, and CMS
The IVR is available 24 hours a day, 7 days a week (except for routine system maintenance), and can be accessed by contacting the NSC Customer Service Line at (866) 238-9652.
Note that the reenrollment process does not negate a supplier’s responsibility to notify the NSC within 30 days of any change. Suppliers are required by supplier standard #2 to notify the NSC within 30 days when information regarding enrollment has changed.
Brian Banks is the Supplier Relations Specialist (Ombudsman) for the National Supplier Clearinghouse (NSC), a government contract administered by Palmetto GBA, Columbia, SC. Banks’ responsibilities include researching/troubleshooting unusual supplier issues, maintaining the NSC portion of the Palmetto GBA Web site, interfacing with organizations around the country, and writing the quarterly newsletter. He can be reached via e-mail: brian.banks@palmettogba.com.
Disclaimer: Though all publications are checked for accuracy, please remember information is subject to change depending on rules and regulations. If you have any questions, call our NSC Customer Service Line at (866) 238-9652.
More reenrollment helpful hints 1. CMS has requested suppliers to not submit a reenrollment to the NSC until the supplier has been contacted by the NSC to do so.
2. Section 15 of the CMS 855S reenrollment application may be signed by either the authorized or delegated official listed on the supplier file.
3. The reenrollment process takes approximately 60 days, which includes a site visit, if required. Also, workload and the amount of development required to complete the reenrollment package also play a part in determining the processing time. Be sure to respond to development requests in a timely manner to avoid having your supplier number inactivated.
Suppliers are required to respond to development requests within 14 days. Depending on the method of development, suppliers have 14 days from either the initial phone contact, fax request date, or, in the case of written development, the postmark of the development letter. If the supplier does not respond in a timely manner to a development request, the supplier number will be inactivated and the supplier will be required to start the process again.
4. Listing a contact person in Section 13 of the CMS 855S assists the analyst when additional information is required to complete the reenrollment process. This contact person should be someone who is knowledgeable about the information listed on the CMS 855S and who can be easily contacted. Many times, there is no contact person listed and the analyst is required to contact the authorized or delegated official on file, who is often not available. Also, please be aware that the NSC analyst is able to request information only from the contact person during the processing of the reenrollment. Once processing is successfully completed, the contact person, unless otherwise authorized, would not be allowed access to any information on the supplier file.
5. Although a majority of the CMS 855S form is already completed with the information on file, there are some areas that are left blank for security reasons. For example, the Social Security Number and date of birth are not preprinted in Section 6. This is a precaution taken by the NSC to prevent the possibility of the information being used fraudulently. However, sections 1124 and 1124A of the Social Security Act require suppliers to provide this information. Ensuring this information is complete will assist in avoiding unnecessary development requests.
Also, Sections 2.D (insurance information) and 6.B (Adverse Legal History) are not completed on the preprinted form. Please be sure to mark all check boxes and complete all date fields in the proper format to avoid delays in processing.
In May 2006, CMS issued revised enrollment applications with several changes that affect the way you handle the all-important NSC reenrollment. 
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