CBIC Alerts Commonly Owned, Commonly Controlled Providers
Bid contractor urges providers to review their enrollment records now, and ensure they understand the commonly owned and commonly controlled distinctions.
- By David Kopf
- Mar 26, 2019
The Competitive Bidding Implementation Contractor (CBIC) is calling on providers to review their enrollment status to determine if they are commonly owned or commonly controlled, and to understand the bidding guidelines related to those classifications.
CBIC outlined the two types:
- Commonly owned suppliers are those where one or more of them has an ownership interest totaling at least five percent in the other. CMS defines "ownership interest" as "the possession of equity in the capital, stock, or profits of another supplier."
- Commonly controlled suppliers are those where one or more of a supplier's owners are also an officer, director, or partner of another supplier.
Commonly owned and commonly controlled suppliers cannot compete against themselves when submitting bids in the same competitive bidding area (CBA) and product category combination.
When registration opens, commonly owned and commonly controlled suppliers must register one time with one Provider Transaction Access Number (PTAN), which is their primary location in the DMEPOS Bidding System (DBidS).
When the bid window opens, commonly owned and commonly controlled suppliers must submit one bid that includes all commonly owned or commonly controlled locations that would furnish the lead item and all non-lead items in the same competition.
The legal business name (LBN) for the primary location will auto-populate in DBidS, on the Business Organization section of Form A. This LBN must be the same LBN on any bid surety bonds. If awarded a contract, the Centers for Medicare & Medicaid Services (CMS) will contract with the legal business entity identified by the LBN for the primary location.
CBIC stressed that commonly owned and commonly controlled supplier organizations that submit separate bids for the same competition will have their bids for the competition disqualified.
Providers must maintain accurate information on their CMS-855S with the NSC and in PECOS. Bearing that in mind, CBIC told providers that they should:
- Review their current Medicare enrollment record on the Provider Enrollment, Chain, and Ownership System (PECOS) for ownership interest or managing control information.
- Complete the appropriate sections of the CMS-855S enrollment application to update any information under their current Medicare supplier billing number, if applicable.
Providers needing assistance or clarification on the CMS-855S enrollment application should visit the National Supplier Clearinghouse (NSC) website or call the NSC at (866) 238-9652. Providers with other questions related to bidding can call the CBIC customer service center at 877-577-5331 between 9 a.m. and 5:30 p.m. Eastern Time, Monday through Friday.
David Kopf is the Executive Editor of HME Business and DME Pharmacy magazine. Follow him on Twitter at @postacutenews.