Implementing Provider File Updates and PECOS to FISS Interface to Accommodate Section 603 Bipartisan Budget Act of 2015

MLN Matters® Number: MM9613
Related Change Request (CR) #: CR 9613
Related CR Release Date: August 5, 2016
Effective Date: January 1, 2017
Related CR Transmittal #: R1704OTN
Implementation Date: January 3, 2017

Provider Types Affected

This MLN Matters® Article is intended for hospitals with off-campus outpatient departments submitting claims to Medicare Administrative Contractors (MACs) for services to Medicare beneficiaries.

Provider Action Needed

Change Request (CR) 9613 reminds you that all off-campus outpatient departments of a hospital provider are required to be correctly identified. Make sure that your billing staffs are aware of these requirements.


Hospital providers are required to include all practice locations on the CMS 855A enrollment form. The Centers for Medicare & Medicaid Services (CMS) has performed a re-validation process (March 25, 2011 – March 23, 2015) where in the last 4 years all hospital providers have completed an 855A enrollment form to either 1) initially enroll in Medicare, 2) add a new practice location, or 3) revalidate its enrollment information. If a hospital claim is submitted with a service facility location that was not included on the CMS 855A enrollment form, it will be returned to the provider until the CMS 855A enrollment form and claims processing system is updated.

Section 1833(t) of the Social Security Act (the Act), as amended by Section 603 of the Bipartisan Budget Act of 2015, requires that certain off-campus departments of a hospital provider be paid under the "applicable payment system" rather than under the Hospital Outpatient Prospective Payment System. CMS established payment policies to pay nonexcepted off-campus departments of a hospital provider under the Medicare Physician Fee Schedule effective for services furnished on or after January 1, 2017. It is important for hospitals to ensure that an accurate address for each hospital department practice location is included on the CMS 855A enrollment form.

Additional Information

The official instruction, CR 9613, issued to your MAC regarding this change, is available at


Last Updated Oct 04, 2018