Reporting Hospice Administrators and Medical Directors as Managing Employees on CMS-855A

In the CY 2024 Home Health Prospective Payment System Final Rule (CMS-1780-F), the Centers for Medicare & Medicaid Services (CMS) clarified that hospice administrators and medical directors must be reported as Managing Employees on the CMS-855A Medicare Enrollment Application.

Key Requirements

• Managing Employee Definition Expanded: Under 42 Code of Federal Regulations (CFR), § 424.502, the term now explicitly includes hospice administrators and medical directors.
• Applicability: This requirement applies to the following:
  • Initial enrollment
  • Revalidation
  • Reactivation
  • Changes of Ownership (CHOWs)

Implications for Hospices

• Failure to Report: If a hospice omits this information, the Medicare contractor will develop the application to request it, causing processing delays.
• Where to Report: Use Section 6A of the CMS-855A form: Ownership Interest and/or Managing Control Information.
• Updating Records: If there is a change in managing employees or if the information was previously unreported, hospices must submit a Change of Information CMS-855A to update their Medicare enrollment records.

References

• CMS Internet-Only Manual, Medicare Program Integrity Manual, Chapter 10: Medicare Enrollment, Section 10.6.7.2: Individual Owning and Managing Information (PDF)
• 42 CFR § 424.502 Definitions