Do I Need to Notify Medicare if I Change Jobs or Collaborating Physicians?

Carolyn Buppert, NP, JD

Disclosures

August 06, 2007

Question

Is the NP who already has an NPI number required to notify Medicare if he or she changes employer or collaborating physicians?

 

Response from the Expert

 

Response from Carolyn Buppert, NP, JD
Attorney, Private Practice, Bethesda, Maryland

The answers are different for a change of collaborating physician and a change of employer.

Regarding collaborating physicians, the current Medicare Provider Enrollment Application for nurse practitioners (CMS 855I) does not ask for the name of the nurse practitioner's (NP's) collaborating physician. This form was revised in 2006. The previous version of the form asked for the name and Medicare provider number of a NP's collaborating physician. While the current CMS 855I states that a provider must report any additions, deletions, or changes to information previously reported to Medicare, within 90 days of the change, and that a provider must submit a new 855I noting the changes, there is no place on the new form to provide information on collaborating physicians. Therefore, one can assume that NPs are not required to notify Medicare when they change collaborating physicians.

However, NPs still need collaborators, because Medicare will reimburse services provided by an NP only when performed in a collaborative relationship with a physician. Collaboration is defined as "a process in which a NP works with one or more physicians (MD/DO) to deliver healthcare services, with medical direction and appropriate supervision as required by the law of the State in which the services are furnished. In the absence of State law governing collaboration, collaboration is to be evidenced by NPs documenting their scope of practice and indicating the relationships that they have with physicians to deal with issues outside their scope of practice." (Source: Medicare Benefit Policy Manual, Chapter 15, section 200.)

Regarding change of employer, the NP must submit a new CMS 855I, noting any change in Medicare contractor (carrier), correspondence address, skilled nursing facility, owner, entity to which the NP reassigns benefits, practice location, and/or managing employee. In addition, the NPs must submit a new CMS 855R, the form used to reassign benefits to an employer.

For information on these forms, see: http://www.cms.hhs.gov/MedicareProviderSupEnroll/03_EnrollmentApplications.asp

Regarding the NPI, the NP needs to apply for and receive that number before completing a Medicare provider enrollment application. For information on the NPI, visit: http://www.cms.hhs.gov/NationalProvIdentStand

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