For decades, radiology groups and other providers and suppliers had to jump through all the hoops required for Medicare enrollment when billing for services performed by radiologists via teleradiology technology from different states. And they had to gain those billing rights by making use of a special form to accompany and update their Medicare enrollment applications in order to bill for the services of their employed and contracted radiologists who reassigned billing rights to the group, using the trusty CMS 855R form. But no longer. In a move to bring efficiency to the enrollment process, the Centers for Medicare and Medicaid Services (CMS) has streamlined its processes so that reassignment now takes place electronically using the Internet-based Provider Enrollment, Chain and Ownership System (PECOS) or the updated and consolidated CMS-855I enrollment application form.

To refresh, when a physician or non-physician practitioner (NPP) is employed or contracts to perform services, and their patients are not billed directly, the physician/practitioner can reassign their Medicare benefits to an eligible enrolled entity to submit claims and receive payment for their Medicare Part B services.  Rare is the circumstance when a physician does not reassign billing rights.  Enrolled entities generally update reassignments via the “Reassignment Topic” of their PECOS applications, or now though updates to the 855I.

An individual practitioner who performs services (physician, physician assistant, nurse practitioner, or clinical nurse specialist) and who is reassigning Medicare benefits now look to PECOS or 855I for that process.  The 855R is no longer used for the reassignment of Medicare benefits, for terminating a reassignment of Medicare benefits, or for making a change in reassignment of Medicare benefit information. 

Both the individual physician/practitioner and the eligible organization/group must be currently enrolled (or concurrently in the process of enrolling) in the Medicare program before the reassignment can take effect.

When establishing a new reassignment, both the individual physician or practitioner reassigning benefits and a delegated/authorized official of the enrolled group must sign such reassignments. Termination or changes made to reassignment information requires either the enrolled entity's authorized official or the individual practitioner to sign the form.  Once terminated, reassigned claims for services rendered by the individual will no longer be paid to the group after the effective date of the termination. After termination, reassigned claims for services may no longer be paid to the group.

Medicare administrative contractors (MACs) process all Medicare updates from enrolled entities. In the era of teleradiology, the typical radiology group must be attentive to regularly submitting reassignment updates to multiple MACs as they add and subtract radiologists who regularly perform services from states other than their principal state of operations. 

For years, that meant that the group taking reassignment had to establish its right to do business in the state where the reassigning physician was located and regularly provided services. Medicare enrolled entities are required to enroll with and submit claims to the MAC jurisdictions over (1) where it has its own practice location(s), and (2) where the reassigning physician has his or her regular practice location. Recently, Medicare's enrollment and reassignment requirements have been made more flexible during the pandemic to make it easier for telemedicine arrangements to exist. Enrollment is still required with the MAC that has jurisdiction over where the reassigning radiologist regularly provides services, but such enrollment with the MAC where the radiologist provides the remote services no longer requires registration by the group to do business in that state. This is a major reform, making teleradiology far less burdened by regulatory requirements. This updated guidance is found in Ch. 10 of the Medicare Program Integrity Manual.  See Sec. 10.3.1.4.3.

All in all, these are significant changes that make enrollment and multi-state teleradiology much easier to manage. Kudos to CMS for making multi-state reassignment and billing more straightforward. And for eliminating the long-time use of the separate reassignment 855R filing and embracing administrative simplification by incorporating reassignment into the 855I update process.