Step 1: Determine You are in the Right Place
If you are reporting a change of ownership or merger acquisition, you need to be an enrolled health care organization (buyer/seller). It is essential that you report changes of ownership/control within 30 days of the effective date of the change.
Step 2: Understand and Make Changes
Change of Ownership
A CHOW typically occurs when a Medicare provider has been purchased or leased by another organization. This can result in the transfer of the old owner’s Medicare Identification Number and provider agreement (including any outstanding Medicare debt) to the new owner. If the purchaser or lessee elects not to accept a transfer of the provider agreement, the old agreement is terminated and the purchaser or lessee is considered a new applicant.
Each party has to complete Medicare forms related to the CHOW using the PECOS or paper forms:
- Seller/former owner: Complete sections 1A, 2F, 13, and either 15 or 16
- Buyer/new owner: Complete all sections except 2G and 2H
Acquisition/Merger
An acquisition/merger occurs when a currently enrolled Medicare provider is purchasing or has been purchased by another enrolled provider. Only the purchaser’s Medicare Identification Number and tax identification number remain.
Acquisitions/mergers are different from CHOWs in that the seller/former owner’s Medicare identification number dissolves. In a CHOW, the seller/former owner’s provider number typically remains intact and is transferred to the new owner.
Each party has to complete Medicare forms related to the acquisition/merger using PECOS or paper forms:
- Seller/former owner: Complete sections 1A, 2G, 13, and either 15 or 16
- Buyer/new owner: Complete sections 1A, 2G, 4, 13, and either 15 (if you are the authorized official) or 16 (if you are the delegated official), and 6 for the signer if that authorized or delegated official has not been established for this provider
Consolidation
A consolidation occurs when two or more enrolled Medicare providers consolidate to form a new business entity. The TIN and Medicare identification numbers of both consolidating entities dissolve and a new TIN and Medicare identification number are assigned to the new, consolidated entity.
Each party has to complete Medicare forms related to the consolidation using PECOS or paper forms:
- Former organizations: Complete sections 1A, 2H, 13, and either 15 or 16
- New organization: Complete all sections except 2F and 2G
You can choose to submit your changes online or via paper application:
- To submit your application electronically, you will access PECOS. Here you will be able to submit your change application. The system will guide you through the process and ensure that you complete the required forms.
- To submit your application by mail, you will fill out form CMS-855A (instructions for completion are on the form) and follow the instructions regarding where to mail the application. You will complete sections according to the changes you are making (as noted in the explanation of changes segment above).
Because of the various situations in which a CHOW, acquisition/merger, or consolidation can occur, it is recommended that you contact your local fee-for-service contractor or its CMS Regional Office if you are unsure as to whether such a transaction has occurred. You can also review the applicable federal regulation at 42 CFR. 489.18 for additional guidance.
Step 3: Submit Required Documentation
It is imperative that you submit the proper documentation along with your enrollment application regarding changes to your business structure. Whether you chose to file electronically or on paper, you must prepare and submit documentation as follows:
- Online via PECOS: PECOS will generate a list of required supporting documentation.
- Paper Form CMS-855A: See section 17 of the CMS 855A application to determine the required documentation
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