by Jared Staheli
June 25th, 2015
In order to enroll IHS clinics that are currently provider-based (and use the hospital’s tax identification number (TIN)) and that wish to bill the designated Medicare Part B carrier, the hospital must complete a Form CMS-855B and enroll as a “group”. Each clinic would be reflected on the Form CMS-855 as a practice location. The “doing business as” name of the clinic could be reflected on the Form CMS-855, if appropriate. Provider identification numbers (PINs) and pay-to addresses must then be issued for each practice. However, the payment would be made to the hospital.
Any clinic that bills as freestanding should submit a new and separate Form CMS-855B for just the freestanding clinic (see exception for physical/occupational therapist under Reassignment in §40.1.4). The processing of these applications should be in accordance with the designated carrier’s regular review and verification procedures. A separate Medicare number will be issued to the freestanding clinic.
NOTE: Tribally operated ambulatory care clinics, including those that are participating as FQHCs, are entitled to enroll their physicians and non-physician practitioners with the applicable Medicare Part B carrier like any other Medicare provider. Although FQHCs are paid on a cost basis for the professional services of physicians and practitioners, the FQHC benefit does not cover and pay for clinical laboratory and diagnostic tests. Consequently, the tribal health center can remain an FQHC and still bill their Medicare Part B carrier for laboratory and diagnostic tests.