On December 29, 2009, CMS issued an alert providing guidance on registration for an entity that does not have a U.S. address and/or Tax Identification Number.
In sum, the alert states, “To accommodate foreign entities that do not have a U.S. address and/or a U.S. Tax Identification Number (TIN) or Employer Identification Number (EIN), CMS is modifying the existing registration process. Foreign entities are not required to register until April 1, 2010.”
The alert also notes, “Foreign entities will follow the same registration and reporting procedures, and have the same responsibility and accountability for data as domestic RREs. The delay in registration for foreign entitles does not change the July 1, 2009 reporting date requirements associated with “Ongoing Responsibility for Medicals” (ORM) or the January 1, 2010 reporting date requirements associated with “Total Payment Obligation to Claimant” (TPOC) amounts.”
To read the alert in its entirety, please visit:
http://www.cms.hhs.gov/MandatoryInsRep/Downloads/ForeignEntity_Alert122909.pdf
