CMS Pub. 100-08, ch. 10, § 10.3.1.4

A. Background

Consistent with 42 CFR § 424.80(b)(1) and (b)(2) and Pub. 100-04, Chapter 1, sections

30.2.1(D) and (E) and 30.2.6 and 30.2.7, Medicare may pay: (1) a physician or other provider’s

or supplier’s employer if the provider or supplier is required, as a condition of employment, to

turn over to the employer the fees for the individual’s services; or (2) an entity (i.e., a person,

group, or facility) that is enrolled in the Medicare program for services furnished by a physician

or other provider or supplier under a contractual arrangement with that entity. This means that

Part A and Part B entities other than physician/practitioner group practices can receive

reassigned benefits, assuming the requirements for a reassignment exception are otherwise met.

Reassignments of benefits are now facilitated via the Form CMS-855I. The Form CMS-855R

has been discontinued.

B. General Reassignor Policies

An individual who renders Medicare Part B services and seeks to reassign benefits to an eligible

entity should complete Sections 4(F)(1) and (2) of the Form CMS-855I for each party eligible to

receive reassigned benefits; the individual must be enrolled in Medicare as a

physician/practitioner prior to reassigning benefits. The applicable sections of the Form CMS-

855I (e.g., Section 1(A) (Reason for Submittal); Section 1(B) (Reassignment of Benefits

checkbox); Sections 4(F)(1) and (2); Section 15; etc.) must also be completed for any individual

who is adding, terminating, changing an existing reassignment. (Note that Section 4(F)(3) is

optional.)

The individual can report multiple new, changed, or terminated reassignments to parties with the

same or different employer identification numbers (EINs) on a single Form CMS-855I by

submitting separate Section 4(F)s and Section 15(C)s with the appropriate reassignee signatures.

(For instance, if a physician is reassigning to Groups A, B, and C, an authorized/delegated

official of A, B, and C, respectively, must sign a separate Section 15(C).) The contractor shall

issue one approval letter using the applicable model letter in sections 10.7.6(D) and 10.7.6(M) of

chapter 10.

For reassignment terminations, the effective date of termination as indicated on the Form CMS-

855I is the day after the effective date of termination. Payment will no longer be made to the

reassignee the day after the termination effective date. To illustrate, suppose a physician submits

a Form CMS-855I to terminate a reassignment to a group. June 30, 2025, is listed as the

termination date. The termination effective date listed in PECOS and any correspondence to the

supplier should be July 1, 2025.

There could be rare situations where an unenrolled individual seeks to reassign benefits and

submits only Section 4(F) of the Form CMS-855I. The contractor in this situation shall develop

for an initial enrollment application from the individual.

The contractor need not verify whether the reassigning individual is a W-2 employee or a 1099

contractor.

Regarding reassignment and revoked or deceased physicians, see section 10.6.17(G)(1) of this

chapter.

C. Policies Concerning Reassignees

1. Site of Service

Per Pub. 100-04, chapter 1, section 30.2.7, a reassignment of benefits to any eligible party is

permitted regardless of where the service was rendered or whether the party owns or leases that

location. As such, the contractor need not verify the reassignee’s ownership or leasing

arrangement with respect to the reassignment.

2. Organization/Group Receiving the Reassigned Benefits

The most common reassignment situation is a physician/practitioner who reassigns benefits to a

physician/practitioner group. Here, the reassignee’s authorized or delegated official must sign

Section 15(C) of the reassignor’s Form CMS-855I.

3. Individual Receiving Reassigned Benefits

An individual can receive reassigned benefits. This can occur, for instance, when a

physician/practitioner reassigns benefits to a physician/practitioner who is either (1) a sole

proprietor or (2) the sole owner of an entity listed in the Business Information section of the

Form CMS-855I. Here, the only required forms are separate Form CMS-855Is from the

reassignor and the reassignee. (No Form CMS-855B or Form CMS-855A is involved.) The

reassignee must sign Section 15(C) of the reassignor’s Form CMS-855I. (Note that Section

15(C) applies to all reassignees, regardless of whether they are organizations or individuals. In

the former case, the organization’s authorized/delegated official must sign Section 15(C); with

the latter, the individual reassignee must sign.)

The contractor shall follow the instructions in Pub. 100-04, Chapter 1, sections 30.2 – 30.2.16 to

ensure that the reassignee is indeed eligible to receive reassigned benefits.

4. Additional Information

If the reassignee is not enrolled in Medicare, said party must complete, as applicable, an initial

Form CMS-855B, Form CMS-855A, or Form CMS-855I.

Benefits are reassigned to a provider or supplier, not to the provider/supplier’s practice

location(s). As such, the reassignor need not update the individual’s reassignment data on the

Form CMS-855I each time the reassignee adds a practice location.

When a group practice adds a new practice location, each physician/practitioner who reassigns to

the group and wants to bill from this new location must have a new PTAN if the group is issued

a new PTAN. (The group will only be issued a new PTAN if the new location is in a separate

fee locality.)

D. Additional Signature Policies

1. Who Must Sign

For initial/new reassignments, both the reassignor and reassignee (or an authorized/delegated

official of the latter) must sign, respectively, Section 15(B) and (C) of the reassignor’s Form

CMS-855I. If either required signature is missing, the contractor shall develop for it.

For changes in reassignment data or for reassignment terminations (and as similar situations

were handled with the Form CMS-855R), only the reassignor or reassignee must submit the

termination or applicable changed information in Section 4(F) and sign Section 15(B) or (C) (as

applicable).

2. Official On/Not on File

An authorized/delegated official who signs Section 15(C) of the Form CMS-855I must be

currently on file with the contractor as such. If this is a new enrollment --- with a joint

submission of the Form(s) CMS-855A or CMS 855B and Form CMS-855I --- the person must be

listed on the Form CMS-855A or Form CMS-855B as an authorized/delegated official.

There may be situations where a Form CMS-855I is submitted and the reassignee is already

enrolled in Medicare via the Form CMS-855B. However, the authorized/delegated official is not

on file. In this case, the contractor shall develop for a Form(s) CMS-855A or CMS-855B change

request that adds the new authorized/delegated official.

3. Development Needed

If the contractor must develop for information in Section 4(F)(1) or (2), the following apply:

(i) Initial reassignments (as part of an initial Form CMS-855I or a Form CMS-855I change of

information that adds a new reassignment): Both the reassignor and reassignee (or, for entities,

an authorized/delegated official thereof) must sign any certification statement that must

accompany the reassignor’s response.

(ii) All other transactions – Only the reassignor or reassignee need sign any required certification

statement.

4. Other Signature Policies

The contractor shall follow all other applicable signature policies (e.g., form of signature)

outlined in section 10.3.1.3.6 of this chapter.

5. Processing Alternatives

As applicable, the contractor may apply the processing alternatives identified in section

10.3.1.3.7 to the Section 4(F) data.

E. Inter-Jurisdictional Reassignments

If a reassignor is reassigning benefits to a reassignee located in another contractor jurisdiction (a

permissible practice), the principles in this section 10.3.1.4(E) apply unless another CMS

directive states otherwise.

1. The reassignor must be properly licensed or otherwise authorized to perform services in the

state in which the individual has the practice location. The practice location can be an office or

even the individual’s home (for example, a physician interprets test results in the physician’s

home for an independent diagnostic testing facility).

2. The reassignor need not – pursuant to the reassignment - enroll in the reassignee’s contractor

jurisdiction nor be licensed/authorized to practice in the reassignee’s state. If the reassignor will

be performing services within the reassignee’s state, the reassignor must enroll with the

contractor for (and be licensed/authorized to practice in) that state.

3. The reassignee must enroll in the contractor jurisdictions in which (1) it has its own practice

location(s), and (2) the reassignor has the practice location(s). In Case (2), the reassignee:

(i) Shall identify the reassignor’s practice location as a practice location on its Form CMS-855B

or Form CMS-855I.

(ii) Shall select the practice location type as “Other health care facility” and specify

“Telemedicine location” in the Practice Location Information of its Form CMS-855.

(iii) Need not be licensed/authorized to perform services in the reassignor’s state.

To illustrate, suppose Dr. Smith is in Contractor Jurisdiction X and is reassigning benefits to

Jones Medical Group in Contractor Jurisdiction Y. Jones must enroll with X and with Y. Jones

need not be licensed/authorized to perform services in Dr. Smith’s state. However, in the

Practice Location Information section of the Form CMS- 855B it submits to X, Jones must list

Dr. Smith’s location as its practice location.

F. Reassignment to CAHs

Reassignment to a Part A provider or supplier might occur when: (1) a physician or practitioner

reassigns benefits to a hospital, skilled nursing facility, or critical access hospital billing under

Method II (CAH II); or (2) a nurse practitioner reassigns to a CAH II.

If the entity receiving the reassigned benefits is not a CAH II, it must enroll with the contractor

via a Form CMS-855B, and the physician/practitioner reassigning benefits must complete and

submit a Form CMS-855I.

If the entity receiving the reassigned benefits is a CAH II, the entity need not complete a separate

Form CMS-855B to receive reassigned benefits. The physician/practitioner can reassign benefits

directly to the CAH II’s Part A enrollment. The distinction between CAHs billing Method I vs.

Method II only applies to outpatient services. It does not apply to inpatient services.

Under Method I:

• The CAH bills for facility services

• The physicians/practitioners bill separately for their professional services

Under Method II:

• The CAH bills for facility services

• If a physician/practitioner has reassigned benefits to the CAH, the CAH bills for that

particular physician’s/practitioner’s professional service

• If a CAH has elected Method II, the physician/practitioner need not reassign benefits to the

CAH. For those physicians/practitioners who do not reassign their benefits to the CAH, the

CAH only bills for facility services and the physicians/practitioners separately bill for their

professional services (akin to Method I).

Although physicians and non-physician practitioners are not required to reassign their benefits to

a CAH that bills Method II, doing so allows them to participate in the Electronic Health Records

(EHR) Incentive Program for Eligible Professionals (EPs).

In this scenario, the Form CMS-855I shall be submitted to the Part B MAC and the Form CMS-

855A submitted to the Part A MAC. The Part B MAC is responsible for reassigning the

individual to the Part A entity.

The reassignment to the Part A entity shall only occur if the Form CMS-855A for the CAH II has

been finalized. This can be determined by viewing PECOS to identify if an approved enrollment

exists for the CAH II. If one does not, the Part B MAC shall return the Form CMS-855I to the

provider on the ground that it is inapplicable to the transaction in question (i.e., the Form CMS-

855A has not been finalized). If an enrollment record exists but is pending state/SOG review,

the Part B MAC shall contact the Part A MAC to determine if state/SOG Location (as

applicable) approval has been received but not yet updated in PECOS prior to returning the

applications.

G. Reassignments Related to Revoked or Deactivated Reassignee

The contractor shall end-date in PECOS all reassignment associations and the associated

Provider Transaction Access Numbers (PTANs) when revoking or deactivating an individual or

organization (reassignee) that is receiving reassigned benefits from an individual practitioner.

The end-date shall be the same as the effective date of the revocation or deactivation; this will

ensure the appropriate end-date in the Multi-Carrier System (MCS) and prevent improper use of

those PTANs. However, the contractor shall not deactivate the individual practitioner’s

(reassignor’s) enrollment record even if (1) the reassigned PTAN is the only PTAN on the

individual’s enrollment record and/or (2) no other active locations exist (private practice

locations or reassignments); the contractor shall allow the practitioner’s/reassignor’s enrollment

record to remain in an approved status.

When sending a deactivation, revocation, or voluntary withdrawal letter to the deactivated or

revoked non-certified Part B supplier, said letter shall include the following language: “Please

notify all physician assistants and/or group members who reassign benefits to your organization

that, in accordance with 42 CFR §424.540(a)(2), their Medicare enrollment status may be

deactivated if they fail to update their enrollment record within 90 calendar days.”

H. Group and Reassignment Reactivation

If a group practice submits a reactivation application after being deactivated for non-response to

a revalidation request, the contractor shall reactivate the group’s reassignments when the group’s

reactivation application has been approved; Form CMS-855I applications for the

reassignments are not required. The effective dates assigned to the reassigned providers shall

align with the group’s effective date per existing reactivation instructions. (This section

10.3.1.4(H) only applies to deactivations based on a non-response to a revalidation request.)

I. Additional Information

The contractor:

• Shall follow this chapter’s existing instructions (and all other applicable CMS guidance) for

validating information furnished by a physician/practitioner on the Form CMS-855I,

including any reassignment data in Sections 4(F)(1) and (2).

• Shall follow the instructions in section 10.6.2 of this chapter regarding the application of

effective dates.