Clarification Issued on PEMS Change of Ownership Process

The update specifies the conditions in CHOW scenarios, differentiating between procedures when the buyer (new owner) and the seller (Old owner) have identical National Provider Identifier (NPI) or different NPIs.

CHOW Scenarios Involving Different NPIs

Two procedures exist for the use of different NPIs/ Atypical Provider Identifier (API) between the new and old owners:

• In case the new owner is already registered in PEMS, he or she is to apply PEMS-Existing Enrollment application.
• In case the NPI/ API of the new owner is not registered, he has to fill out a PEMS-New Enrollment application.

Note: The old NPI will be disenrolled after the new enrollment is done. Others filed under the old NPI on services provided after the CHOW effective date will not be reimbursed.

CHOW Scenarios Using the Same NPI

When the seller and the buyer have the same NPI, the buyer lacks an active enrollment against this identifier, and the buyer is required to file a PEMS-New Enrollment application to create a new profile, indicating the new ownership. Disenrolling the former ownership profile will then be done.

Criteria

The clarification emphasizes reviewing §489.18 Change of ownership or leasing: Effect on provider agreement to identify whether a transaction is a true CHOW.

A CHOW is not represented by the following:

• Corporate Mergers and Stock Transfer.
• Alteration of principals or controlling interest.

These changes should rather be reported under PEMS-Maintenance – Ownership/Controlling Interest update.

Additional Resources

Additional guidance is available to the providers through:

• What Is a CHOW? video on the TMHP YouTube channel
• The “Long-Term Care (LTC) Change of Ownership (CHOW)” article
• The “CHOW Requirements Changing for High Screen Risk Providers” article

To help, the providers can refer to the TMHP Contact Center at 800-925-9126 or the TMHP-CSHCN Services Program Contact Center at 800-568-2413.