AHA Comments on The Revision of the Medicare Enrollment Application for Institutional Providers CMS-855A

February 13, 2023

The Honorable Chiquita Brooks-LaSure
Administrator
Centers for Medicare & Medicaid Services
Hubert H. Humphrey Building
200 Independence Avenue, S.W., Room 445-G
Washington, DC 20201

Re: CMS–855A, Agency Information Collection: Medicare Enrollment Application for Institutional Providers (Vol. 87, No. 240), December 15, 2022.

Dear Administrator Brooks-LaSure:

On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the American Hospital Association (AHA) appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS) information collection request regarding the revision of the Medicare Enrollment Application for Institutional Providers (CMS-855A).

There are several areas of proposed changes to the enrollment application with which the AHA has concerns. These include:

• Section 2A’s proposed elimination of the physician-owned hospital (POH) question;
• Section 4A regarding whether practice locations are provider-based, and if so, the type of provider-based department (PBD);
• Section 4C2 about the electronic storage of patient medical records; and
• Section 5A asking whether an organization is itself owned by any other organization or individual.

View the detailed letter below.