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OMB Control No: 0938-1135	ICR Reference No: 202005-0938-005
Status: Historical Inactive	Previous ICR Reference No: 201804-0938-024
Agency/Subagency: HHS/CMS	Agency Tracking No: CPI
Title: Medicare Registration Application (CMS-855O)
Type of Information Collection: Revision of a currently approved collection	Common Form ICR: No
Type of Review Request: Emergency	Approval Requested By: 05/15/2020
OIRA Conclusion Action: Withdrawn and continue	Conclusion Date: 05/13/2020
Retrieve Notice of Action (NOA)	Date Received in OIRA: 05/11/2020
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	12/31/2021	6 Months From Approved	12/31/2021
Responses	95,200	0	95,200
Time Burden (Hours)	33,600	0	33,600
Cost Burden (Dollars)	0	0	0

Abstract: The publication of the Patient Protection and Affordable Care Act (PPACA), section 6405 - "Physicians Who Order Items or Services Required to be Medicare Enrolled Physicians or Eligible Professionals" (regulation CMS 6010-F), contains a requirement for certain physicians and non-physician practitioners to enroll in the Medicare program for the sole purpose of ordering or referring items or services for Medicare beneficiaries. The PPACA has an effective date applicable to written orders and certifications made on or after July 1, 2010. The CMS 855O allows a physician to receive a Medicare identification number (without being approved for billing privileges) for the sole purpose of ordering and referring Medicare beneficiaries to Medicare approved providers and suppliers. This new Medicare application form allows physicians who do not provide services to Medicare beneficiaries to be given a Medicare identification number without having to supply all the data required for the submission of Medicare claims. It also allows the Medicare program to identify ordering and referring physicians without having to validate the amount of data necessary to determine claims payment eligibility (such as banking information), while continuing to identify the physician's credentials as valid for ordering and referring purposes.

Emergency Justfication: Currently, there are certain payment requirements for covered Part A or Part B home health services. Specifically, to receive payment for such services, the provider’s claim must meet all of the following requirements: ● The ordering/certifying physician must be identified by his or her legal name and National Provider Identifier (NPI) on the claim. ● The ordering/certifying physician must be enrolled in Medicare in an approved status or have validly opted-out of the Medicare program. Section 3708 of the CARES Act expanded who may certify the need for home health services to include Nurse Practitioners (NPs), Clinical Nurse Specialists (CNSs), and Physician Assistants (PAs) in order to provide additional flexibilities to respond effectively to the serious public health threats posed by the spread of the 2019 Novel Coronavirus (COVID-19). The interim final rule Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency (RIN: 0938-AU32) includes a provision to allow NPs, CNSs and PAs to certify the need for home health services to align with the CARES Act. This, in turn, would require these three non-physician practitioner (NPP) types to be enrolled in or opted-out of Medicare to certify such services. Physicians and practitioners complete the Medicare Enrollment Application - Registration For Eligible Ordering and Referring Physicians and Non-Physician Practitioners (OMB control number: 0938-1135) if they are enrolling in Medicare solely to order, or certify certain Medicare items and services. Based on our internal data, we generally estimate that approximately 5,000 currently unenrolled or non-opted out NPs, CNSs, and PAs will elect to enroll in or opt-out of Medicare solely for the purpose of certifying home health services in the initial year and 1,000 new NPs, CNSs, and PAs each year will enroll in or opt-out of Medicare for the same purpose. These additional burden estimates require a revision to the currently approved information collection request (ICR). As the current COVID-19 crisis expands, there is a need for flexibility of health care services provided to Medicare beneficiaries. Expanding who can certify home health services reduces burden on the physicians, who up until now, were the only provider type eligible to certify home health services. The expedited clearance of the Medicare Enrollment Application is critical to ensuring beneficiaries receive access to needed care while reducing the burden on physicians. Therefore, we ask that OMB consider the emergency clearance process to allow NPs, CNSs and PAs to certify the need for home health services to align with the CARES Act.

Authorizing Statute(s): PL: Pub.L. 111 - 148 6405 Name of Law: Affordable Care Act

Citations for New Statutory Requirements: Statute at Large: 116 Stat. 136 Name of Statute: Coronavirus Aid, Relief, and Economic Security Act (CARES Act)

Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
0938-AU32	Final or interim final rulemaking	85 FR 27550	05/08/2020

Federal Register Notices & Comments
Did the Agency receive public comments on this ICR? No

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: As previously explained, under section 3708 of the CARES Act, we are expanding § 424.507(b)(1) to allow NPs, CNSs, and PAs to certify the need for home health services. This will require the completion of the CMS-855O application. The number of respondents associated with initial enrollment application requirements has increased by 8,000 respondents (from 28,000 to 36,000 NPPs). Therefore, the burden hours have increased. No revisions have been made to the Changes of Enrollment Information and Reporting of Voluntary Withdrawal requirements.

Annual Cost to Federal Government: $1,300,000

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination. No

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination. No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? Yes

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Yes

Agency Contact: Jamaa Hill 301 492-4190

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