Prerequisites
- The PC formed, with EIN and CP 575
- Type 2 NPI for the PC; Type 1 for each clinician
- The PC’s bank account open (for CMS-588)
- Practice location secured — a site visit is possible for some provider types
- Ownership and managing control information assembled
The forms
Nearly all of this can be filed electronically in PECOS, which is faster and easier to track than paper.
Steps
1
Set up PECOS access
Through CMS I&A. The authorized official for the PC will need an account, and staff can be granted delegated access.
2
File the CMS-855B for the group
Requires: legal business name matching the CP 575, EIN, Type 2 NPI, practice locations, correspondence address, authorized and delegated officials, and ownership and managing control disclosure.
3
Handle the ownership disclosure carefully
The 855B requires disclosure of persons and organizations with ownership or managing control interests. In an MSO-PC structure the honest answer for ownership is the clinician-owner, but “managing control” is broader than equity, and an MSO exercising significant management authority may need to be disclosed.This is a question for counsel, not a form to guess at. Under-disclosure is a misrepresentation; over-disclosure may raise questions you’d rather answer proactively than reactively. Get it right the first time.
4
File CMS-855I for each clinician
Individual enrollment. A clinician already enrolled elsewhere still needs to be associated with your group.
5
File CMS-855R to reassign benefits
This is what directs Medicare payment for the clinician’s services to the group’s Tax ID rather than the individual’s. Without it, the group cannot bill for that clinician’s services.
6
File CMS-588 for EFT
Bank account details for the PC’s operating account, with a voided check or bank letter.The account must be the PC’s, not the MSO’s. Medicare pays the enrolled supplier. See Why MSO-PC banking is different.
7
Decide on participating status (CMS-460)
A participating provider accepts assignment on all Medicare claims. Non-participating providers may accept assignment case-by-case but are subject to the limiting charge and receive a reduced fee schedule amount. Most groups participate.
8
Record the PTANs
On approval you receive a Provider Transaction Access Number (PTAN), a MAC-assigned identifier distinct from the NPI. You need it for MAC portal access, claim status inquiries, and appeals. Record group and individual PTANs in your enrollment grid.
9
Set up ERA and EDI through your clearinghouse
Separate from the 855 enrollment. See Set up EDI, ERA, and EFT.
10
Calendar revalidation
Most providers revalidate every five years; DMEPOS suppliers every three.Revalidation notices go to the correspondence address in PECOS. If nobody monitors it, the first you’ll hear is when billing privileges are deactivated. Confirm the address is one a human reads, and check your due date directly in the Medicare Revalidation Lookup Tool.
Timeline
Typically 60–120 days, sometimes longer. Site visits, ownership questions, and incomplete applications extend it. Medicare has its own rules on retrospective billing for physician and non-physician practitioner enrollment, allowing billing for a limited period before the effective date in defined circumstances. Confirm the current CMS policy rather than relying on what a colleague did in a prior year.Opt-out
A physician who has opted out of Medicare has private contracts with beneficiaries and does not bill Medicare at all. Relevant because:- An opted-out clinician cannot reassign benefits to your group
- Opt-out is per-physician and runs for a defined period
- It is more common in some specialties, notably psychiatry
Verify it worked
- 855B approved; group PTAN recorded
- 855I approved for each clinician; individual PTANs recorded
- 855R reassignment approved for each clinician
- 588 EFT confirmed, depositing to the PC’s account
- Participating status decided and filed
- Effective dates recorded in the enrollment grid
- PECOS correspondence address monitored by a named person
- Revalidation date calendared with a 90-day lead
- ERA delivery configured