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National Supplier Clearinghouse
What is the difference between the authorized official and the delegated official?

The similarities and differences between an authorized and a delegated official can be somewhat confusing. This comparison is to assist the supplier community to better understand the functions of these individuals.

Please note the authorized and delegated officials are not location specific, but are affiliated with the tax identification number (TIN). Suppliers can have different individuals listed as the authorized or delegated officials under different TINs as long as they meet the respective definitions.

Also, all authorized and delegated officials must be reported in Section 9.

Authorized Official Delegated Officials
Definition of an Authorized Official
An authorized official is an appointed official to whom the DMEPOS supplier has granted legal authority to enroll it in the Medicare Program to make changes and to commit the DMEPOS supplier to fully abide by the laws, regulations and program instructions of Medicare.

42 C.F.R. § 424.510(a)(2) requires the authorized official to be one of the following individuals: general partner, chairman of the board, chief financial officer, chief executive officer, president, or hold a position of similar status and authority within the provider or supplier organization.

An Authorized Official Can
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.

Number of Authorized Officials a Supplier Can Have
As many as desired as long as the individual meets the definition of an authorized official.

Definition of a Delegated Official
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.

A Delegated Official Can
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
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.

Number of Delegated Officials a Supplier Can Have
As many as desired as long as the individual meets the definition of an delegated official.


last updated on 03/24/2014
ver 1.0.43