Make Changes - JE Part A

CHOW Application Submission

There are two ways to submit an application to Medicare.

1. Internet-based Provider Enrollment, Chain, and Ownership System (PECOS) web
2. CMS-855A paper application

Check out the Enrollment on Demands (EoDs) to get help submitting an application.

Internet-Based PECOS Web Advantages

Internet-based PECOS web is the preferred application submission method. See advantages.

• Faster application process
• Efficient
• Automatic selection of proper enrollment form(s)
• Fewer submission errors/omissions
• Secure

Prior to submission, upload all required supporting documentation and electronically sign the certification statement.

Timeframes

If an enrolled provider is adding, deleting, or changing information under their existing Medicare number, submit the update via Internet-based PECOS or the CMS-855A.

The below changes must be submitted within 30 days of the effective date of the change.

• Any change in adverse legal history
• Change of ownership
  • Including a change in an authorized or delegated official
• Practice location

Report all other informational changes within 90 days of the effective date of the change.

Different Types of Change of Ownerships (CHOW)

"Standard" CHOW

CHOW means, the removal, addition, or substitution of a partner, the merger of the provider corporation into another corporation, or the consolidation of two or more corporations. The most common example of a CHOW occurs when a provider's CMS Certification Number (CCN), Provider Transaction Number (PTAN) or Medicare ID are bought by another entity. This is what is known as a buyer/seller CHOW.

Acquisition/Merger

In general, this occurs when two or more Medicare-enrolled entities combine, leaving only one remaining CCN and provider agreement. For instance, Entity A and Entity B are both enrolled in Medicare, each with its own CCN and provider agreement. The two entities decide to merge. Entity B's CCN and provider agreement will be eliminated, leaving only Entity A's CCN and provider agreement.

If the acquisition results in an existing provider having new owners but keeping its existing provider number, the applicant should check the CHOW box in section 1A of the CMS-855A.

Unlike the new owner in a CHOW or consolidation, the new owner in an acquisition/merger is not required to complete the entire CMS-855A. This is because the new owner is already enrolled in Medicare. As such, the provider being acquired should be reported as a practice location in section 4 of the new owner's CMS-855A.

Consolidations

This occurs when the merger of two or more Medicare-enrolled entities results in the creation of a brand-new entity. For instance, if Entities A and B decide to combine and, in the process, create a new entity (Entity C), the CCNs and provider agreements of both A and B will be eliminated. Entity C will have its own CCN and provider agreement.

Note the difference between acquisitions/mergers and consolidations. In an acquisition/merger, when A and B combine there is one surviving entity. In a consolidation, when A and B combine there are no surviving entities. Rather, a new entity is created – Entity C.

A provider may undergo a financial or administrative change that it considers to be a CHOW, but does not meet the regulatory definition identified in §489.18.

Crosswalk Requests

MACs are no longer able to request an update to re-open the claims crosswalk to assist the seller with cleanup claims. The buyer and seller are responsible for working together on payment arrangements for the seller's claims once the CHOW is approved. This applies to any application received on/after May 15, 2017.

Things to remember

• Both old and new owners must submit copies of interim and final sales/lease agreements in a CHOW
• A Buyer will change Electronic Funds Transfer (EFT) account or special payment address to that of new owner before receiving tie-in/approval notice. It is responsibility of Buyer and Seller to work out any payment arrangements between themselves while Noridian and Regional Office (RO) are processing the CHOW
• Information contained in sales/lease agreement should be consistent with what is reported on new owner's CMS-855A (e.g., same names), and (2) terms of contract indicate that new owner will assume provider agreement
• If submitting a change on CMS-855A, add/change/delete boxes must be completed for applicable section that is changing
• If adding a practice location address, a fee is required
• FQHC's changing their practice location address must submit a new HRSA
• Do not submit CHOW more than 90 days prior to anticipated date of sale, or 30 days after sale effective date. Any application received more than 90 days before projected sale date will be returned

Resources

• CMS Change Request (CR) 9953 - See section 9953.5
• CMS Internet Only Manual (IOM), Publication 100-08, Medicare Program Integrity Manual, Chapter 10, 10.2.1