System level personnel cannot be CMS-855 Authorized Officials unless they have a position/designation at the provider level as well.
What is a CMS-855 Authorized Official? To Medicare, it’s an individual who has been granted the authority to legally bind an organization to participate in and abide by the regulations of the Medicare program in addition to having the authority to approve the submission of updates to enrollment information and status. The growing trend is to centralize provider enrollment functions at the system level.
What Advis recommends: Keep in mind that the Authorized Official must have a position within the provider or supplier organization in order to meet Medicare’s criteria.
What is Medicare’s criteria? Go to the source: The Medicare Provider Integrity Manual, Chapter 18.104.22.168.1 provides that “One cannot use his/her status as the chief executive officer, chief financial officer, etc., of the provider’s parent company, management company, or chain home office as a basis for his/her role as the provider’s authorized official… An authorized official must be an authorized official of the provider, not of an owning organization, parent company, chain home office, or management company.”
Not feeling like a rules expert yet? That’s what The Advis Group is; visit our Provider Enrollment info center or contact Advis at 708-478-7030 or firstname.lastname@example.org to connect with one of our provider enrollment experts.
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The Advis Group Consultants Expert Advice: Provider Enrollment
Medicare provider enrollment is an area of increasing concern to CMS. CMS is scrutinizing provider enrollment as never before. To help ensure provider compliance with enrollment regulations and maintain reimbursement flows, The Advis Group offers regular tips to assist providers and suppliers in navigating the complex world of provider enrollment.