NPEast must determine whether a newly listed authorized official (AO) on a Form CMS-855S has the authority to serve in that capacity. The term “newly listed” means any person who has not previously been approved as an AO on the supplier’s enrollment. A newly listed AO could be submitted on initial enrollment or a changes of information applications.
The following persons (as indicated by their title) are automatically determined to have authority to be an AO:
Administrator of the provider (This is different from, for instance, a contract administrator, billing administrator, or other “administrator” title normally associated with a staff-level position.)
President or vice-president of the provider.
Chief executive officer, chief financial officer, chief operations officer, chief of staff, chief compliance officer, or chief of administration of the provider.
Director of finance, director of operations, director of administration, director of compliance, director of human resources, or business director of the provider (The use of “director” here is different from the definition of director in § 424.502, which applies to board members. Not every board member will have signature authority.)
General manager, business manager, operations manager, financial manager, or compliance manager of the provider.
General partner in a partnership or limited partnership (Limited partners cannot serve as Aos.)
Excluding partnerships, a 5 percent or greater direct owner of the provider.
Treasurer of the provider.
Chairman or vice-chairman (regardless of business type) of the provider’s governing board.
Any officer of the provider corporation (i.e., any corporate officer, including a corporate secretary.)
Medical director of the provider.
Any other position that, in the contractor’s experience, is close in name or authority to one of those listed above.
The following are common examples of titles that would not automatically quality as an AO:
Chief nursing officer or chief information officer.
Director of nursing, director of rehabilitation, director of food services, or director of billing/claims.
Officer manager (e.g., of a modest-sized physician practice) or, for larger entities, managers of departments that are strictly limited to the provision of health care services, patient interaction, food services, security, maintenance, or other activities generally not involving oversight of the entity’s financial, compliance, business, or overall operations.
Any of the persons listed above with allowable titles who are officials or owners of entities other than the provider (e.g., CEO of the company that manages the provider’s operations; president of the provider’s indirect owner).
If we are unsure whether the individual has signature authority, we will ask for an email explaining the person’s roles and responsibilities within the organization, and why the supplier believes the individual has signature authority, to make a final decision.
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