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Prevent Revalidation Processing Delays

When National Government Services receives a revalidation application, we often determine additional information is needed to process the application. In those cases, a request for additional information is sent which is commonly referred to as development. Sending development requests and waiting for responses delay processing times.

One way to prevent a common delay is by ensuring you meet the name matching requirements before submitting an application.

For Who
Requirements
For individuals and individual sole proprietors enrolled under a SSN or an EIN, the legal name reported on enrollment applications, EFT agreements and all of these sources must match exactly.

Note: If you have employees, an EIN is required.
  • The individual’s legal name reflected in Social Security records
  • The individual’s legal name reflected in the NPPES Registry for the Type 1 NPI
  • The individual’s legal name reflected on a voided check or bank confirmation letter
  • The individual's legal name reflected in the IRS records as demonstrated by an IRS-CP575, IRS-147C or other approved form (if enrolled under an EIN) and this must match the individual’s legal name in Social Security records
For individuals who are sole owners of an organization, the individual’s legal name and legal business name reported on enrollment applications, EFT agreements and all of these sources must match exactly.
  • The individual’s legal name reflected in Social Security records
  • The individual’s legal name reflected in the NPPES Registry for the Type 1 NPI
  • The organization’s legal business name reflected in the NPPES Registry for the Type 2 NPI
  • The organization’s legal business name on a voided check or bank confirmation letter     
  • The organization’s legal business name reflected in the IRS records as demonstrated by an IRS-CP575, IRS-147C or other approved form
  • The organization’s legal business name on applicable state corporation websites
For organizations, the legal business name reported on enrollment applications, EFT agreements and all of these sources must match exactly.
  • The organization’s legal business name reflected in the NPPES Registry for the Type 2 NPI
  • The organization’s legal business name on a voided check or bank confirmation letter     
  • The organization’s legal business name reflected in the IRS records as demonstrated by an IRS-CP575, IRS-147C or other approved form
  • The organization’s legal business name on applicable state corporation websites

The table below contains the top reasons for development and how to prevent them. Using PECOS to submit your revalidation application can also help prevent development requests since you are verifying information already on file rather than fully completing a blank paper application.

Common Missing or Incomplete Items How to Prevent Development When Submitting a Paper Application How to Prevent Development When Submitting a PECOS Application
EFT Information
Fully complete and submit the form CMS-588 (1/17) EFT Authorization Agreement. Be sure to:
  • Specify the legal name on the EFT agreement and that name must match exactly the name on file with the IRS or SSA and on the voided check or bank letter.
  • Check either SSN or EIN box.
  • Check either checking account or savings account box.
  • Include a voided check. If the voided check is not an exact match, it is recommended that you obtain and include a bank letter specifying your name to match.
If EFT information is already present, verify the information is accurate.

If EFT information is missing or requires updates, enter the information into the EFT topic. Ensure the legal name on the EFT agreement matches exactly  the name on file with the IRS or SSA and on the voided check. Upload a copy of the voided check. If the voided check is not an exact match, it is recommended that you obtain and upload a bank letter specifying your name to match.
NPPES Registry Name Mismatches Check the NPPES Registry to verify your NPI and name. An individual’s name and an organization’s legal business name on file with NPPES must match what is reported to Medicare and the IRS or SSA records exactly.

If an NPPES correction is necessary, complete the correction prior to submitting your revalidation application.
Check the NPPES Registry to verify your NPI and name. An individual’s name and an organization’s legal business name on file with NPPES must match what is reported to Medicare and the IRS or SSA records exactly. 

If an NPPES correction is necessary, complete the correction prior to submitting your revalidation application.
Not Addressing all PTANs and/or Affiliations Identified in the Revalidation Request Letter Ensure that the form CMS-855I or CMS-855B addresses each current and/or terminated PTAN and/or affiliations:

CMS-855I specify current information in section (as applicable):
  • 2I-Physician Assistant employment arrangements
  • 4B-Sole Proprietor/Sole Owner practice locations
  • 4F-Reassignments/
    Affiliations
CMS-855B specify current information in section:
  • 4A-Entity practice locations
To terminate a PTAN(s)/affiliation, use corresponding sections as indicated above, except on CMS-855I section 4F-Reassigments/Affiliations, request termination on a cover letter submitted with application.
Ensure the revalidation application addresses each current or terminated PTANs and/or affiliations.
Sole Owners Missing Individual or Group Information Sole Owners should complete revalidation for both the individual and the group at the same time by completing the form CMS-855I.
  • Specify individual information in Section 2.
  • Specify group information in Section 4A.
Sole Owners should revalidate both the individual enrollment and the group enrollment in PECOS at the same time.
Missing Nonphysician Practitioner Certification Documents Include a copy of required certification(s) for a nonphysician practitioner. Upload a copy of required certification(s) for a nonphysician practitioner.
Missing or Expired State Required Registrations Ensure all state required registrations are current. Complete necessary updates prior to submitting your revalidation application.

Each state has unique requirements, processes and websites that may vary for individuals and businesses. Each provider will need to follow their individual state’s requirements. The J6 State Licensing and Certification Websites and the JK State Licensing and Certification Websites page contains helpful links for some organizations within the J6 and JK states that can be used to verify your licensing or certification status.

Note for New York Providers:
Physicians, nonphysician practitioners and professional practice corporate entities in the state of New York are required to maintain registration with the New York State Education Department (NYSED) Office of Professions; access this website to ensure your registration is current.
Ensure all state required registrations are current. Complete necessary updates prior to submitting your revalidation application.

Each state has unique requirements, processes and websites that may vary for individuals and businesses. Each provider will need to follow their individual state’s requirements. The J6 State Licensing and Certification Websites and the JK State Licensing and Certification Websites page contains helpful links for some organizations within the J6 and JK states that can be used to verify your licensing or certification status.

Note for New York Providers:
Physicians, nonphysician practitioners and professional practice corporate entities in the state of New York are required to maintain registration with the New York State Education Department (NYSED) Office of Professions; access this website to ensure your registration is current.
Incorrect Provider Social Security Number or Date of Birth Specify the correct Social Security Number and date of birth in Section 2A of the form CMS-855I. Verify
Missing Practice Location Information in Section 4 of the CMS-855I and CMS-855B Specify all practice locations in Section 4 of the form CMS-855I or the form CMS-855B. When adding a new practice location, specify the date you saw your first Medicare patient at that location. Verify

  • If adding a new practice location, specify the date you saw your first Medicare patient at that location.
Missing Answers to Final Adverse Legal Actions/Convictions Questions Questions regarding final adverse legal actions/convictions appear in multiple sections of both forms CMS-855I and CMS-855B. Ensure that you select the applicable box ‘Yes’ or ‘No’ for each section you complete.
  • CMS-855I – Sections 3, 4A and 6B (there must be a corresponding Section 6B for each Section 6A)
  • CMS-855B – Sections 3, 5B and 6B (there must be a corresponding Section 5B for each Section 5A and a corresponding Section 6B for each Section 6A)
If answering ‘Yes,’ upload a copy of the final adverse legal action documentation and resolution.
Verify
  • If answering ‘Yes,’ upload a copy of the final adverse legal action documentation and resolution.


Missing signatures for New AO or DO when Adding New AO or DO  The form CMS-855B Section 15 must be signed by one AO and Section 16 for new DO including AO signature during revalidation.

Note: Every AO and DO must be identified in Section 6A and 6B.
Obtain signature(s)
Missing Information for Individuals Having Managing Control in Section 6 of the CMS-855I Copy and complete Section 6 of the form CMS-855I for all managing employees. For each person listed in Section 6A, there must be a corresponding Section 6B. Verify
Missing Information for Individuals with Ownership Interest and/or Managing Control in Section 6 of the CMS-855B Copy and complete Section 6 of the CMS-855B for all individuals who have ownership interest and/or managing control. For each person listed in Section 6A, there must be a corresponding Section 6B. Verify

Revised 3/5/2019

Posted: 2/6/2019

Prevent Revalidation Processing Delays
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J6 Mailing Address:

National Government Services, Inc.
P.O. Box 6475 | Indianapolis, IN 46206-6475

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877-908-9499

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877-908-8476

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