New requirement for CAH enrollment & Demystifying Medicare’s Provider Enrollment, Chain and Ownership System (PECOS)

Critical Access Hospital Medicare reporting of practice locations

On September 20, 2019, CMS published revisions to the Medicare State Operations Manual (SOM), Chapter 2: The Certification process. These revisions clarify the process for critical access hospitals (CAHs) when adding off-campus practice locations.

The revisions implemented into the enrollment manual clarify that CAHs should seek an advance determination of compliance with CAH location requirements for any off-campus provider-based facility. The new language provides instruction to the CAH for the proper handling of reporting a new off campus location.  While seeking advance determination from CMS is not a unique idea, it’s important to note that CMS is now asking a CAH to submit documentation of compliance with the distance requirements during the CMS-855A process and to the MAC, not directly to CMS.

In order to be in compliance with the provider-based requirements, an off-campus location must be reported to the MAC via a CMS-855A enrollment filing, which results in the location being added to the CAHs hospital record. Hospitals must be in compliance with this and other applicable Medicare provider-based regulations before operating and billing as a hospital department or facility.

CAH enrollment and business development teams must keep in mind this clarification when planning and timing the opening of off-campus locations to allow the MAC and CMS time to review and make a determination.

The CMS notice and manual changes can be found at

Medicare’s Provider Enrollment, Chain and Ownership System (PECOS)

A simple change in your provider enrollment program can improve timely filing processing times, accuracy, and efficiency as well as prevent cash flow delays. Often times, leadership are not aware that their provider enrollment departments may still be submitting paper-fillable CMS-855 Forms for their Medicare certified facilities and practitioners. CMS has already phased out hand-written paper application submissions by requiring the use of the fillable 855 forms. Advis has uncovered this issue in many healthcare facilities when evaluating their onboarding and provider enrollment process.

Some signs that your provider enrollment team may not be optimizing the tools available to ensure timely processing of your Medicare enrollment filings are:

  • Are your applications taking 60 days or more to get approved by the Medicare Administrative Contractor (MAC)?
  • Are you holding claims waiting for a practitioner to complete their Medicare enrollment?

If your seasoned and experienced provider enrollment team is reluctant to move to electronic submission by using the Provider Enrollment, Chain and Ownership System (PECOS), it is only a matter of time before CMS phases out the paper applications as they are an administrative burden for both the provider and MAC.

There are several advantages to PECOS registration including but not limited to:

  • Faster Processing Timeframes (on average up to 45 days)
  • Ability to Submit all CMS-855 Application Types (i.e. CMS-855A, B, I, R, O, S) and for All Purposes (i.e. Initial Enrollment, Changes of Information, CHOWs, Voluntary Terminations, Reactivations)
  • Tailored applications to your submission purpose (i.e. PECOS will only ask the questions that are relevant to your application type and purpose)
  • Ability to View and Correct/Update Enrollment Information Expeditiously
  • Ability for Authorized/Delegated Officials and Practitioners to Electronically Sign Applications
  • Immediate Verification of Individual Names, SSNs, and Dates of Birth while in Application
  • Obtain Application Statuses without having to call the MAC
  • Instant Access to View Information Currently on File with Medicare
  • Ability to Print Medicare Enrollment Summaries to Send to Commercial Payers as Proof of Enrollment

Advis can demystify PECOS in an easily understandable and timely manner via personalized webinars for all provider types on how to utilize PECOS including step-by-step/page-by-page instructions. Advis will also share valuable “tricks of the enrollment trade” from our experience of using PECOS since its inception.

For any questions regarding how Advis can assist your organization, please contact Advis at (708) 478-7030.