CMS-1500 (08/05) Invalid Paper Form
Frequently Asked Questions (FAQs)
Q 1) I received an email that said that
some invalid CMS-1500 (08/05) forms were printed which may
reject if submitted to Medicare. I didn’t see any
information on the CMS website about this on March 9
th
when I
received the email. Can you confirm that the email came from
CMS and is correct?
A 1) Yes, it was sent by CMS and it is
correct. Due to the approaching April 1 deadline for
rejection of CMS-1500 (12/90) forms, we wanted to get
information to physicians, practitioners and suppliers who
might be affected by this problem as quickly as possible. A
provider list serve is maintained by the Provider Outreach
Group in CMS. We used that list serve to send the March 9th
email as that was the fastest way to spread the message.
Since March 9, we have also posted information on the CMS
web site (
www.cms.hhs.gov;
click on the CMS-1500 listing in the highlight box on the
opening page of the Web site to obtain this information),
are in the process of publishing a One Time Notice (OTN)
that will be available in Publication 100-20; and have
discussed this with the Medicare contractors, the Government
Printing Office, the National Uniform Claims Committee (NUCC)
and the company engaged by the NUCC to produce the printing
specifications for the new form. We are trying to resolve
the problem, and determine its scope as well as spread the
information to as many CMS-1500 users as possible. A Med
Learn Matters article will be issued very soon, following
final clearance of the OTN.
Q 2) What is the actual problem?
A 2) There appear to be a couple of
problems. Some entities printed CMS-1500 forms using the
example posted in the forms section of the CMS Web site.
That form was not intended for use in this way as it does
not contain the “drop out” ink colors that are needed to
enable the data on claims submitted with those copies to be
read by the optical character recognition (OCR) equipment
used for entry of most paper claims to the Medicare
adjudication system. That form is also not to scale. The
second problem which was mentioned in the March 9
th
email involves
misalignment of the printed forms. In most cases, it appears
that the “crop marks” create a top margin that is too short
and a bottom margin that is too long. As result, when the
forms are fed into certain types of OCR equipment, the claim
data is not located in the precise location where that
equipment is programmed to look for that data, resulting in
rejection of those paper claims as the OCR equipment
concludes that required data elements are missing.
Q 3) Do the problems apply to all
insurers or just to Medicare?
A 3) To the extent other insurers accept the
CMS-1500 (08/05) form, these problems could also be
experienced by those other insurers. We can only address the
problems as they apply to Medicare though. If other insurers
experience these problems, they will need to notify
submitters of the misprinted forms themselves.
Q 4) What are physicians, practitioners,
suppliers and billing agents who have had their paper claims
rejected by a Medicare contractor because they were
submitted on invalid CMS-1500 (08/05) forms supposed to do
so they can be paid?
A 4) They need to contact the organization,
person, store or printer from whom they obtained their paper
forms to let them know that Medicare considers their forms
to be invalid and to ask what provisions will be made for
replacement of the invalid forms with valid forms. In the
event the seller is not aware that their forms are invalid,
it may take that seller some time to print enough paper
forms to replace the invalid stock that was sold. That
seller should at least stop selling any invalid forms that
may still be in their inventory. The claim submitters can
use the CMS-1500 (12/90) stock and software to resubmit
those claims if still able to produce paper claims in that
version and the submitters prefer not to wait until
replacement forms are available. Medicare will not begin to
reject those forms beginning April 1, 2007 as originally
planned. We expect to continue to accept those forms until
at least June 1, while we take action to get misprinted
forms off the market and to have them replaced by valid
forms. Medicare will continue to accept paper claims using
the 12/90 version of the CMS-1500 without NPIs. We will
provide advanced notice to the health care industry of the
new termination date for the 12/90 version CMS-1500 once the
problem is resolved.
Q 5) How does this affect the NPI
implementation date of May 23, 2007.
A 5) This issue applies only to certain
CMS-1500 paper forms and does not involve the institutional
paper claims form (CMS-1450/UB-04) or the electronic claim
formats adopted as national standards under HIPAA. More than
99 percent of the institutional claims and more than 92
percent of the professional claims sent Medicare are
transmitted electronically using a HIPAA adopted format.
Although Medicare has elected to require NPIs on paper
claims as well as on electronic claims, the HIPAA NPI
regulation does not require use of NPIs on paper claim
forms. As result, CMS has more discretion concerning whether
and when to require NPIs on paper claims. This CMS-1500
(08/05) issue will not result in delay of the date by which
NPIs must replace provider legacy identifiers on valid
CMS-1500 (08/05) forms or on UB-04, X12 837 version 4010A1
or NCPDP HIPAA version claims.
Q 6) Where do I place the NPI on the old
1500 form?
A 6) The old form does not have fields for
reporting of NPIs. As result, those individuals who continue
to use the 12/90 version of the CMS-1500 will not be
required to report NPIs on the claims they submit using the
old form.
Q 7) Is the June 1, 2007 date firm or
simply a target?
A 7) It is currently a “target” date. Once a
final decision has been made, the actual date will be
communicated.
Q 8) Can you direct me to a print vendor
where I can purchase valid CMS-1500 (08/05) forms?
A 8) CMS does not license or collect
information on those printers that produce copies of the
paper claim forms. As result, we cannot advise which
printers or vendors have valid copies of the CMS-1500
(08/05) and which do not. There is nothing on the invalid
forms that rejected to date that identifies the printer(s)
of those forms. As result, we must rely on those providers,
whose paper claims have been rejected by a Medicare
contractor as invalid, to advise the entity from which they
purchased their forms that they are invalid. The Government
Printing Office (GPO) does sell printed forms as well as
negatives of the form for use by printers. GPO stopped
selling the forms as soon as the misalignment problem was
detected. GPO is in the process of replacing their stock
with valid forms but we do not yet know when the valid forms
will be available for sale by the GPO.
Q 9) The 1500 form is no longer posted to
the CMS forms Web site. When will it be posted again?
A 9) We are working to have a corrected form
posted there, but this form cannot be used for submission of
CMS-1500 (08/05) claims. It is posted at that site so
providers can see what the new form looks like. The form on
the CMS Web page is not to scale and is not printed in the
“drop out” ink color required to enable those claims to be
read by OCR equipment. No provider or printer should ever
produce that form using the copy on the CMS Web page. This
same principal applied to the CMS-1500 (12/90) version of
the form.
Q 10) I purchased forms and they appear
correct. Can you tell by looking at a 08/05 version of the
form if it is not valid?
A 10) The specific formatting issue we have
seen involves top and bottom margins only, but the problem
may not be limited to only the top and bottom margins. The
best way to identify these is by looking at the upper right
hand corner of a form. If the tip of the red arrow above the
vertically stacked word “CARRIER” is touching or close to
touching the top edge of the form, then the form is not
printed to specifications. There should be approximately one
quarter of one inch between the tip of the arrow andthe top
edge of the paper on a properly formatted form.
Q 11) Our 08/05 version forms are valid;
can we use them now or should we wait?
A 11) If your forms are valid, insofar as
they have not been rejected by any Medicare contractor, you
should continue to submit claims using those copies of the
form.
Q 12) I generally bill electronically but
I have not been able to obtain NPIs for each of the
providers identified on my claims, such as a supervising
physician or a purchased services provider. Since you will
not begin to reject CMS-1500 (12/90) version forms that lack
NPIs effective May 23, 2007, can I use that form to submit
claims to Medicare when I do not know the NPI of one or more
providers involved with a patient’scare?
A 12)The Administrative Simplification
Compliance Act (ASCA) requires that providers submit claims
to Medicare electronically to be considered for payment,
except in very limited situations, such as when a practice
that submits CMS-1500 forms has fewer than 10 full-time
equivalent employees. If the submitter of a paper form has
been reviewed by Medicare and it was determined the provider
does not qualify for an exception from the ASCA requirement,
any paper claims submitted by or for that provider will be
denied. No provider that does not meet ASCA exception
criteria may submit paper claims, even if they do not know
the NPI of one or more providers that must be identified on
a claim sent to Medicare. Information on ASCA, the exception
criteria and ASCA reviews can be viewed at www.cms.hhs.gov/manuals
by clicking on Internet Only Manuals, selecting Publication
100-04 on the next page and then scrolling to chapter 24.
The ASCA information is in sections 90-90.6 of that chapter.
