Disclosing details of parties with certain mortgages, deeds of trust, or security interests in Medicare Part A providers is explicitly required in the recently revised Medicare enrollment forms, effective as of July 1, 2011. This expanded classification of “ownership interests and/or managing control information” represents a significant change in disclosure, and presents new questions around compliance for Medicare Part A providers and those that finance or are involved in transactions that contemplate mortgages, deeds of trust, and other security interests.
By way of background, Medicare Part A providers (e.g., hospitals, skilled nursing facilities, home health agencies, federally qualified health centers, end-stage renal disease facilities, outpatient rehab facilities) must enroll in the Medicare program using the Medicare Enrollment Application for Institutional Providers (Form CMS-855A) in order to be eligible for payment for covered services provided to beneficiaries. Periodic re-enrollment and timely updating of any change in information is also required using Form CMS-855A. The purpose of the enrollment application is to inform CMS of: (i) the identity of the Part A provider, (ii) whether it meets certain provider qualifications, (iii) where it renders services, (iv) the identity of the owners, and (v) other information to establish correct claims payments.