CMS recently issued guidance on the reporting responsibilities for individual physicians,
physician group practices and individual non-physician practitioners enrolled in Medicare.
For individual practitioners, both physician and non-physician, a change in practice
location or change in final adverse action must be reported to CMS within 30 days of such
change. A reportable change in practice location includes establishment of a new
location, moving an existing location, closing a location or, surprisingly, a change in any
portion of an existing practice location address where Medicare information is sent. A
change in business structure, legal business name, tax identification number or payment
information and an individual’s retirement or voluntary withdrawal from Medicare are
events that must be reported within 90 days. For group practices, the reporting
responsibilities are similar. In addition to a change in practice location or final adverse
action, a group practice must also report a sale of more than five percent ownership or,
with respect to partnerships, the addition or deletion of a partner within 30 days. Changes
in legal business name, tax identification number, authorized or delegated officials, and
payment information of groups must be reported within 90 days.

Likely the most overlooked of the reportable events for both individual practitioners and
groups is a change in reassignment of benefits. The recent guidance tends to suggest
that it is the duty of both the group and the individual practitioner to file a revised CMS-
855R reassignment each time a physician is added to or withdraws his or her
reassignment of Medicare benefits to a group practice. For multi-specialty faculty practice
plans and other particularly large group practices, the duty to file a revised CMS-855R for
each physician leaving the practice may prove to be a significant administrative burden.
Thankfully, the new guidance also highlights PECOS, the Internet-based enrollment
system that now allows individual practitioners to enroll and make amendments to
enrollment information online. CMS expects PECOS to be available for use by group
practices later this year.