> ## Documentation Index
> Fetch the complete documentation index at: https://mso.getlemma.com/llms.txt
> Use this file to discover all available pages before exploring further.

# Enroll in Medicare (PECOS)

> CMS-855B for the group, CMS-855I for the clinician, CMS-588 for EFT, reassignment of benefits, PTANs, ownership disclosure, and revalidation.

Medicare enrollment is submitted through **PECOS** (the Provider Enrollment, Chain, and Ownership System) and processed by your regional **Medicare Administrative Contractor (MAC)**. A group needs the entity enrolled, each clinician enrolled, and each clinician's benefits reassigned to the group.

## 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

| Form         | Purpose                                                           | Filed by       |
| ------------ | ----------------------------------------------------------------- | -------------- |
| **CMS-855B** | Enroll the group / clinic as a supplier                           | The PC         |
| **CMS-855I** | Enroll an individual physician or non-physician practitioner      | Each clinician |
| **CMS-855R** | Reassign benefits from the individual to the group                | Both           |
| **CMS-588**  | EFT authorization                                                 | The PC         |
| **CMS-460**  | Participating provider agreement (optional but usually desirable) | The PC         |

Nearly all of this can be filed electronically in PECOS, which is faster and easier to track than paper.

## Steps

<Steps>
  <Step title="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.
  </Step>

  <Step title="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**.
  </Step>

  <Step title="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.
  </Step>

  <Step title="File CMS-855I for each clinician">
    Individual enrollment. A clinician already enrolled elsewhere still needs to be associated with your group.
  </Step>

  <Step title="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.
  </Step>

  <Step title="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](/concepts/banking/why-healthcare-banking-is-different).
  </Step>

  <Step title="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.
  </Step>

  <Step title="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.
  </Step>

  <Step title="Set up ERA and EDI through your clearinghouse">
    Separate from the 855 enrollment. See [Set up EDI, ERA, and EFT](/guides/enrollment/set-up-edi-era-eft).
  </Step>

  <Step title="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](https://data.cms.gov/tools/medicare-revalidation-list).
  </Step>
</Steps>

## 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

Check opt-out status during [clinician vetting](/guides/formation/vet-a-friendly-clinician), not after you've built the model.

## 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

## Common failure modes

| Failure                                              | Consequence                                         |
| ---------------------------------------------------- | --------------------------------------------------- |
| Legal name mismatch with IRS records                 | Application rejected                                |
| Ownership and managing control disclosure guessed at | Misrepresentation risk                              |
| 855R never filed                                     | The group cannot bill for that clinician            |
| EFT pointed at the MSO's account                     | Compliance problem plus a re-enrollment cycle       |
| PECOS correspondence address unmonitored             | Missed revalidation; deactivated billing privileges |
| Missed revalidation                                  | Deactivation; claims stop                           |
| Assuming ERA is included in 855 enrollment           | Payments arrive with no electronic remittance       |


## Related topics

- [Enroll in state Medicaid](/guides/enrollment/enroll-in-medicaid.md)
- [Set up EDI, ERA, and EFT with each payer](/guides/enrollment/set-up-edi-era-eft.md)
- [Track licenses, revalidations, and expirables](/guides/enrollment/maintain-revalidations.md)
- [The US payer landscape](/concepts/payments/the-payer-landscape.md)
- [Medicare (fee-for-service)](/reference/payers/profiles/medicare.md)
- [Payer enrollment & submission links](/reference/payers/enrollment-links.md)
