Article Detail - JE Part A
Understanding the CHOW Process Under the IRF Review Choice Demonstration
A change of ownership (CHOW) occurs when a Medicare‑certified provider is purchased or leased by another organization per 42 CFR §489.18(a). A CHOW must be reported via a CMS-855A and processed/approved before operational changes take full effect. When there is a CHOW, the existing provider agreement is automatically assigned to the new owner unless the new owner rejects assignment of the provider agreement.
If the new owner rejects this assignment, the provider cannot participate in Medicare without going through the same process as any new provider (e.g., initial enrollment, undergoing a state survey). Automatic assignment of the existing provider agreement and CMS Certification Number (CCN) to the new owner means the new owner is subject to all the terms and conditions under which the existing agreement was issued. The new owner assumes responsibility for compliance with Medicare requirements effective with the CHOW date.
The effective date of the CHOW is determined in accordance with 42 CFR §489.18. If the CHOW occurs in a state actively participating in the Inpatient Rehabilitation Facility (IRF) Review Choice Demonstration (RCD), the IRF will be subject to RCD requirements.
For IRFs that reject assignment, they will be subject to the target affirmation rate review cycle in effect when Medicare enrollment is finalized.
The following information applies to IRFs accepting assignment during the CHOW process.
Before the CHOW
Review the Current RCD Selection Option
The CHOW buyer (new owner) should coordinate with the seller to identify the RCD selection choice applicable to the current cycle. For purposes of the IRF RCD, the new owner will continue under the existing RCD selection option in effect when the CHOW is finalized.
Review Current and Previous Affirmation Rates
The CHOW buyer should coordinate with the seller to determine previous and current review cycle affirmation rates. The buyer inherits all reviews and affirmation decisions submitted during the current cycle. End‑of‑cycle rates affect the choices available for the next selection period.
During the CHOW
If an RCD selection period occurs before the CHOW is finalized, the buyer and seller will need to coordinate to ensure a choice selection is submitted. The buyer will inherit the RCD review choice selection that is in effect when the CHOW is finalized.
After the CHOW
Several actions should be completed after the CHOW is finalized to ensure continued participation in the RCD processes.
Establish Access to the Noridian Medicare Portal (NMP)
Enroll in the NMP using the buyer's new CCN and National Provider Identifier (NPI) combination. Do not use the former CCN/NPI to request unique tracking numbers (UTNs). Claims will return to provider if the NPI on the UTN does not match the NPI submitted on the claim.
Submit New Requests Using Updated Information
Submit all requests for new UTNs using the new CCN and NPI. If a UTN was requested before the CHOW finalized and the NPI needs to be updated, contact the Provider Contact Center (PCC). If the provider receives an affirmed UTN after the CHOW finalizes and the UTN is attached to the previous NPI, this will return to the provider.
Assign User Access
Ensure all necessary staff have access to the new NMP account. The account administrator must grant permissions to team members who submit Pre‑Claim Review (PCR) requests or perform other administrative functions.
