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Authorized Official vs. Delegated Official: What’s the Difference?

Understanding the Difference Between Delegated and Authorized Officials According to Medicare

Medicare distinguishes between authorized officials and delegated officials on their enrollment forms and many people wonder what the difference is.

Authorized Official Definition

An authorized official means an appointed official (i.e. chief executive officer, chief financial officer, general partner, chairman of the board, or 5% or greater direct owner) to whom the organization has granted the legal authority to enroll it in the Medicare program, to make changes or updates to the organization’s enrollment information in the Medicare program, and to commit the organization to fully abide by the statutes, regulations, and program instructions of the Medicare program.

Authorized Official Authority

  • The authorized official is the only individual that has the authority to sign the initial CMS 855S application. By this signature the authorized official agrees to notify the Medicare program contractor if any of the information on the application is incorrect or untrue. Also, the authorized official agrees to notify the NSC of any changes within 30 days of the change (Supplier Standard 2).
  • An authorized official is the only individual that can add and remove delegated officials.
  • Suppliers may have as many authorized officials as desired as long as the individual meets the definition of an authorized official.

Delegated Official Definition

Delegated officials are persons who are delegated the legal authority by the authorized official to make changes to the supplier file.
A delegated official must be a W-2 employee of the supplier or an individual with 5 percent or greater direct ownership interest in, or an individual with partnership interest in the enrolling supplier. If the delegated official is the managing employee, this individual must be a W-2 employee and the NSC may request proof this individual is a W-2 employee.

Delegated Official Authority

  • A delegated official can make changes or updates to the supplier file, such as address changes or the addition of a part owner.
  • The delegated official may also sign and submit the CMS 855S to enroll additional locations, revalidate or reactivate an existing supplier.
  • A delegated official may not delegate its authority to another individual. Only the authorized official may appoint someone as a delegated official
  • ¬†A delegated official may not sign the initial CMS 855S application for the initial location.
  • A supplier may have as many delegated officials as desired as long as the individual meets the definition of a delegated official.

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