Critical Access Hospital (CAH) Method II Billing and Reassignments

The reimbursement team has recently seen an increase in questions regarding Critical Access Hospital (CAH) Method II claims that are Returning to Provider (RTP). If your organization is experiencing RTP claims under Method II, please ensure that all practitioner reassignments have been properly completed in the Medicare Provider Enrollment, Chain, and Ownership System (PECOS).

Effective July 1, 2025, all practitioners, whether employed or contracted, who are billed under Method II must formally reassign their billing rights to the CAH’s Tax ID. Each practitioner must have a completed CMS-855I (Medicare Enrollment Application - Physicians and Non-Physician Practitioners) on file, and the reassignment must be recorded in PECOS.

Beginning January 2, 2026, CMS will RTP or deny claims if the practitioner reassignment is not correctly documented in PECOS. Additionally, the CAH must maintain an attestation for each practitioner confirming that they will not bill the MAC separately for services rendered at the facility while the reassignment remains active.

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