What is the difference between the authorized official and the delegated official?


Answer:
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 the Ownership Interest and/or Managing Control Information (Individuals) section of the CMS 855S.

Authorized Official

Delegated Officials

Definition of an Authorized Official (as defined by 42 CFR § 424.502)

An authorized official means an appointed official (e.g chief executive officer, chief financial officer, general partner, chairman of the board, or 5 percent 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.

An Authorized Official Can
The authorized official is the only individual with 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 NPWest of any changes within 30 days of the change (supplier standard 2).

An authorized official is the only individual able to add and remove delegated officials.

Number of Authorized Officials Allowed
As many as desired as long as the individual meets the definition of an authorized official.

 

Definition of a Delegated Official (as defined by 42 CFR § 424.502)
Delegated officials are persons who are delegated the legal authority by the authorized official to make changes to the supplier enrollment. The delegated official must be an individual with an ownership or control interest in (as that term is defined in section 1124(a)(3) of the Social Security Act), or be a W-2 managing employee of, the provider or supplier.

The delegated official must be a delegated official of the supplier, not of an owning organization, parent company, chain home office, or management company. One cannot use his/her status as a W-2 managing employee of the supplier’s parent company, management company, or chain home office as a basis for his/her role as the supplier’s delegated official.

A Delegated Official Can
A delegated official may report changes or updates to the supplier enrollment, 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 Allowed
As many as desired as long as the individual meets the definition of a delegated official.

 


Last Updated: 03/21/2025