How to Complete and File Form CMS-855R: Reassignment of Medicare Benefits

If you came looking for Form CMS-855R, the standalone paper form no longer exists as a separate document. CMS discontinued it and merged the reassignment sections into the CMS-855I, the individual practitioner enrollment application.1Centers for Medicare & Medicaid Services. Consolidated CMS-855I/CMS-855R Enrollment Applications The reassignment process itself has not changed. You still supply the same information, follow the same rules, and meet the same signature requirements. You just report it through the CMS-855I or the online PECOS portal instead of a standalone form.

What Reassignment Does

Federal regulations prohibit Medicare from paying anyone other than the provider who furnished the service, with limited exceptions.2eCFR. 42 CFR 424.80 – Prohibition of Reassignment of Claims by Suppliers Reassignment is one of those exceptions. It lets an individual physician or non-physician practitioner (nurse practitioner, physician assistant, clinical nurse specialist, and similar professionals) transfer the right to bill Medicare and receive payment to an organization they work for. The organization bills under its own name, collects the reimbursement, and compensates the practitioner according to the employment or contract terms.

Two qualifying relationships support a reassignment. The first is an employer-employee relationship where the practitioner is required, as a condition of employment, to turn over fees for services. The second is a contractual arrangement where an enrolled entity bills for the practitioner’s services under a written agreement.2eCFR. 42 CFR 424.80 – Prohibition of Reassignment of Claims by Suppliers The reassignment lasts only as long as that professional relationship does; when it ends, the reassignment must be terminated.

Before You File

Both the individual practitioner and the receiving organization must already be enrolled in Medicare, or be enrolling at the same time, before a reassignment can take effect.3Centers for Medicare & Medicaid Services. Processing the CMS-855R Medicare Enrollment Application – Reassignment of Benefits In practice:

  • If the individual practitioner is not yet enrolled, submit a CMS-855I for initial enrollment. Because the 855I now contains the reassignment sections, you handle both actions in a single application.
  • If the organization is not yet enrolled, the group must submit a CMS-855B at the same time. On the reassignment portion, write “pending” in the Medicare identification number (PTAN) field for the organization.4CGS Administrators. Medicare Enrollment Application Reassignment of Medicare Benefits CMS-855R
  • If both parties are already enrolled, the practitioner submits only the reassignment sections of the CMS-855I, or files through PECOS.

Every practitioner and organization must have a National Provider Identifier (NPI) before filing. The NPI is a ten-digit number assigned through NPPES and is separate from Medicare enrollment. If you don’t have one, apply at NPPES before starting the enrollment application.

PECOS or Paper

You have two filing paths. CMS favors the electronic route because it processes faster and catches errors as you enter them.

PECOS Online

The Provider Enrollment, Chain, and Ownership System lets you add or terminate a reassignment without mailing anything.5Centers for Medicare & Medicaid Services. Enrollment Applications One timing note matters: you can only submit a reassignment through PECOS after the receiving group’s CMS-855B has already been approved in the system.3Centers for Medicare & Medicaid Services. Processing the CMS-855R Medicare Enrollment Application – Reassignment of Benefits If the group is still in the enrollment pipeline, wait for approval or file on paper.

Paper CMS-855I

For paper submissions, use the reassignment sections of the CMS-855I.1Centers for Medicare & Medicaid Services. Consolidated CMS-855I/CMS-855R Enrollment Applications Mail the completed form to the Medicare Administrative Contractor (MAC) covering the geographic area where you’ll furnish services. You can identify your MAC through the CMS contractor directory.5Centers for Medicare & Medicaid Services. Enrollment Applications Copy the signed application before mailing it.

Information You Need to Provide

Whether you file on paper or through PECOS, you supply the same core data. The sections below follow the structure of the original 855R, which mirrors what the 855I now collects for reassignment.

Reason for Submission

Check the box for your situation: establishing a new reassignment, terminating one, or making a change. Enter the effective date. Leaving that date blank is one of the most common reasons applications get returned.6CGS Administrators. Guidance for Completing the CMS Enrollment Forms

Organization Receiving the Benefits

Provide the group’s legal business name exactly as it appears on file with the IRS and on the group’s CMS-855B enrollment. Even small discrepancies will trigger a rejection.6CGS Administrators. Guidance for Completing the CMS Enrollment Forms You also need the organization’s Tax Identification Number, NPI, and PTAN. If the group is concurrently enrolling and doesn’t yet have a PTAN, write “pending.”4CGS Administrators. Medicare Enrollment Application Reassignment of Medicare Benefits CMS-855R

Individual Practitioner Reassigning Benefits

This section identifies you: legal name, Social Security Number, NPI, and PTAN (or “pending” if you’re enrolling for the first time). Your name must match your Social Security record exactly, because the MAC cross-references it against your existing Medicare enrollment record.4CGS Administrators. Medicare Enrollment Application Reassignment of Medicare Benefits CMS-855R

Primary Practice Location

Identify the group’s practice location where you’ll render services most of the time. Include the “doing business as” name, full street address, and the location’s PTAN and NPI if those differ from the numbers you reported for the organization. The practice location must already be enrolled or enrolling in Medicare.

Contact Person

Name and phone number of someone the MAC can reach with questions during processing. Straightforward, but double-check it. If the MAC can’t reach anyone, the application stalls.

Certification Statements and Signatures

For a new reassignment, both the individual practitioner and the organization’s authorized official must sign. The certification reads: “Under penalty of perjury, I, the undersigned, certify that the above information is true, accurate and complete. I understand that any misrepresentation or concealment of any information requested in this application may subject me to liability under civil and criminal laws.” Signature dates cannot be more than 120 days before the MAC receives the application.3Centers for Medicare & Medicaid Services. Processing the CMS-855R Medicare Enrollment Application – Reassignment of Benefits

For terminations, only one signature is needed. Either the practitioner or the authorized official can sign alone.3Centers for Medicare & Medicaid Services. Processing the CMS-855R Medicare Enrollment Application – Reassignment of Benefits

Signing Electronically Through PECOS

If you file through PECOS, both parties can sign electronically instead of printing and mailing a certification page. The individual practitioner agrees to the terms and conditions in the portal, then selects an authorized official for the receiving organization and enters that person’s email address.7Centers for Medicare & Medicaid Services. Electronic Signature How To Guide

PECOS sends the authorized official an email containing a unique PIN. That PIN expires after 72 hours, so the official has to act quickly. Officials who already have a PECOS account log in and complete the signature in the “Manage Signature” section. Officials without an account access the PECOS e-signature site, enter their identity information, and use the PIN to sign.7Centers for Medicare & Medicaid Services. Electronic Signature How To Guide Either party can also opt out: print the certification statement from the CMS website, sign it by hand, write the web tracking ID at the top, and mail it to the MAC.

Effective Date

The effective date of a new reassignment is the later of two dates: the date the MAC received your application, or the date you first began furnishing services at the new practice location.3Centers for Medicare & Medicaid Services. Processing the CMS-855R Medicare Enrollment Application – Reassignment of Benefits It can never be earlier than the enrollment effective dates of both the practitioner and the organization. You can bill retroactively for services furnished between the effective date and the approval date, but you cannot push the effective date further back than the filing date.

For physicians and non-physician practitioners, this follows the same effective-date framework that applies to all individual enrollment under 42 CFR ยง 424.520(d).8eCFR. 42 CFR 424.520 – Effective Date of Medicare Billing Privileges File as soon as the practitioner starts at the group. Every day of delay is a day of services that may not be billable under the group’s arrangement.

Processing Times and Follow-Up

PECOS applications that don’t require a site visit or additional development typically process in about 15 calendar days. Paper applications under similar circumstances take roughly 30 calendar days. Applications that trigger a site visit, fingerprinting, or further development can take 50 to 65 days depending on how you submitted.9Palmetto GBA. Provider Enrollment Application Processing Time These timeframes begin when the MAC receives your application and pause whenever the MAC sends a request for additional documentation.

If the MAC asks for more information, you have 30 days to respond.4CGS Administrators. Medicare Enrollment Application Reassignment of Medicare Benefits CMS-855R Miss that window and the MAC can reject or deactivate your application, forcing you to start over. Track your status through the PECOS portal even if you filed on paper. It’s the fastest way to catch a pending development request before the clock runs out.

Terminating a Reassignment

When a practitioner leaves a group, or when a group ends its relationship with a practitioner, someone has to file to terminate the reassignment. Submit a separate termination for each practitioner-group pair being dissolved.3Centers for Medicare & Medicaid Services. Processing the CMS-855R Medicare Enrollment Application – Reassignment of Benefits On paper, complete the applicable sections and check the termination box. Through PECOS, handle the same action online.

Only one signature is required. Either the practitioner or the organization’s authorized official can file the termination independently. Include the termination date in the effective-date field; leaving it blank triggers a development letter that adds processing time. The 120-day signature-date rule still applies.

Terminate promptly. If the reassignment stays active after the professional relationship ends, the group can continue billing under the practitioner’s credentials, and the practitioner may be held personally liable for those claims even without knowing the billing was occurring.10Office of Inspector General. OIG Alerts Physicians to Exercise Caution When Reassigning Their Medicare Payments

Mistakes That Delay or Reject Applications

MACs return reassignment applications for errors that seem minor but are, from the MAC’s perspective, disqualifying. The most frequent problems:6CGS Administrators. Guidance for Completing the CMS Enrollment Forms

  • Missing effective date in Section 1.
  • Reason-for-submission box not checked, so the MAC can’t tell whether this is a new reassignment, termination, or change.
  • Legal business name that doesn’t match what’s on file with the IRS or on the group’s 855B.
  • Missing NPI for the organization.
  • Old or incorrect PTAN entered instead of “pending” when the group is concurrently enrolling.
  • Unsigned or undated certification, or a signature from someone who is not the current authorized or delegated official.

Most of these errors add 30 or more days to your timeline because the MAC mails a development letter and waits for your response. Reviewing the form against this list before submission saves real time.

When You Don’t Need a Reassignment

If you’re covering for a colleague on vacation, out sick, or at a conference, that arrangement is handled through fee-for-time compensation billing (sometimes called locum tenens), not a reassignment. The regular physician bills under their own NPI with modifier Q6, and no 855I reassignment filing is needed.11Noridian Medicare. Fee-for-Time Compensation Arrangements and Reciprocal Billing

Fee-for-time arrangements are limited to physicians (MDs and DOs only; non-physician practitioners are not eligible) and capped at 60 continuous days. The substitute must be an independent contractor paid on a per diem or similar fee-for-time basis. After 60 days, the substitute has to bill under their own name and credentials.11Noridian Medicare. Fee-for-Time Compensation Arrangements and Reciprocal Billing

Your Liability Doesn’t Transfer

Reassigning your billing rights does not reassign your legal exposure. The OIG has made clear that physicians who execute a reassignment can be liable for false claims submitted by the entity receiving their benefits.10Office of Inspector General. OIG Alerts Physicians to Exercise Caution When Reassigning Their Medicare Payments In past enforcement, the OIG pursued physicians under civil monetary penalty laws when entities billed for services the physicians never performed or directly supervised.

You retain the right to review every claim the entity submits under your reassigned provider number. The OIG specifically notes that physicians have unrestricted access to this billing information, and exercising that right is one of the strongest protections against being caught up in someone else’s billing fraud.10Office of Inspector General. OIG Alerts Physicians to Exercise Caution When Reassigning Their Medicare Payments If you see services being billed that you did not furnish, address it with the group immediately and consider contacting the OIG.