Does each DME location need its own 855S?

Yes. The form requires a separate CMS-855S for each physical location used to furnish Medicare items, except locations used only as warehouses or repair facilities, and each location must have its own NPI unless the supplier is a sole proprietor.

Can my consultant's address be the correspondence address?

No. The 855S says the correspondence, medical record correspondence and revalidation addresses cannot be a billing agency, a management services organization or the supplier's representative. A consultant can be named as the optional contact person in section 13.

Who can sign the CMS-855S?

For an initial enrollment, only an authorized official. Later changes can be signed by a delegated official, who must be an owner or a W-2 managing employee. Paper signatures must be original, in ink, and less than 120 days old when submitted.

What documents go with a new 855S?

Licenses for every state and product, a certificate of liability insurance naming your enrollment contractor, IRS confirmation of your TIN, the CMS-588 with a voided check, the fee receipt and, where they apply, the surety bond, contracts and adverse action records.

The CMS-855S, Section by Section

The CMS-855S is the Medicare enrollment application for suppliers of durable medical equipment, prosthetics, orthotics and supplies. It is used to enroll for the first time, add a location, report changes, revalidate, reactivate and voluntarily terminate. The same data goes into PECOS when you apply online, so the sections below apply whichever route you use. Everything quoted here comes from the current CMS edition of the form (CMS-855S, 12/23).

Two rules shape the whole form. Every physical location is a separate enrollment, "except for locations only used as warehouses or repair facilities." And all information is required except fields marked optional.

Section 1: why are you filing?

Section 1A asks for the reason. A new enrollee, or an enrolled supplier enrolling a new location under a tax identification number not already enrolled with the contractor, completes every section. So does a supplier changing its TIN: "If you are reporting a change to your tax identification number, you must complete a new CMS-855S enrollment application in its entirety." Revalidations and reactivations also complete all sections.

An enrolled supplier adding a location under a TIN already enrolled with the contractor completes a shorter set: sections 1 through 4, section 6 for the managing employee only, 12, 13 (optional) and 15. Section 1B is the change menu for everything else, from hours to owners, and each change lists the sections that must accompany it. Note one line in particular: "Do not submit an application for revalidation until you have been contacted by the contractor."

Section 2: the location, the business and what you sell

This is the longest part and the one most often wrong.

2A, business location. A specific street address recognized by the Postal Service, never a P.O. box. You list posted hours for every day and total weekly hours. "By Appointment Only" may be checked only if you meet the exceptions in 42 CFR 424.57(c)(30), the 30-hours-a-week standard. A change of location requires licenses and proof of insurance for the new address.
2B, identification. Legal business name as reported to the IRS, NPI, TIN and supplier number if one exists. "Each business location MUST have its own NPI, unless enrolling as a sole proprietor/proprietorship with multiple locations."
2C, structure. How the business is registered with the IRS and its organizational form. If no box is checked, the supplier is defaulted to "Proprietary."
2D, states where items are provided. Every state or territory you serve from this location, grouped by DME MAC jurisdiction. "For each State/Territory selected, submit all required licenses for the products and services being provided." This is where mail-order suppliers discover how many licenses they need; see mail-order DME and the states you ship to.
2E1, supplier type. One primary type per location and any number of secondary types, chosen from a list that runs from pharmacy and medical supply company to orthotics personnel and sleep laboratory.
2E2, accreditation. Either the accrediting organization's name with effective and expiration dates, or an exemption reason: exempt by supplier type, a previously enrolled pharmacy with an attestation on file, or a pharmacy providing only non-accredited products.
2E3 and 2E4, products. Drugs that do not require accreditation are listed separately. Then the long product list, from blood glucose monitors (mail order and non-mail order are separate lines) to oxygen and power wheelchairs, with a column for whether you fill from your own inventory or by contract. If you contract with another company to fill orders, you submit the contracts.

The product list must match your accreditation. 42 CFR 424.57(c)(22)(ii) requires the accreditation to "indicate the specific products and services for which the DMEPOS supplier is accredited." The form warns that failure to attach the applicable licenses or contracts "could result in denial or revocation."

Section 3: what counts as a final adverse legal action?

Section 3 asks about the organization "under any current or former name or business identity." It covers federal or state felony convictions within the preceding 10 years, specified health-care-related misdemeanors, any current or past revocation, suspension or voluntary surrender of a medical license in lieu of discipline, any revocation or suspension of accreditation, OIG exclusions, federal debarments, other federal sanctions such as civil money penalties, and any Medicaid exclusion, revocation or termination. Actions must be reported "regardless of whether any records were expunged or any appeals are pending," with documentation attached. Each adverse action also raises the surety bond by $50,000 (424.57(d)(3)).

Which addresses go in section 4?

Section 4 collects the 1099 address with the IRS document showing your TIN and legal name, a correspondence address, a medical record correspondence address, the address for revalidation packages, a special payments address and, if records are kept elsewhere, the records storage location. Three of these come with the same restriction: the address "cannot be a billing agency, Management Services Organization, or the supplier's representative." Revalidation notices and correspondence go to you, not to a consultant. New enrollees also attach the CMS-588 electronic funds transfer agreement.

Sections 5 and 6: who owns and manages the supplier?

Section 5 lists organizations with 5 percent or more direct or indirect ownership, any partnership interest, or managing control, including a management services organization under contract. Section 6 lists individuals: 5 percent or greater direct or indirect owners, officers and directors of a corporation, every managing employee, every partner, and every authorized and delegated official. "A supplier MUST have at least ONE organizational or individual owner, ONE managing employee and ONE Authorized Official."

The form's example: if Company C owns 100 percent of the supplier and Individual D owns 100 percent of Company C, D is reported as an indirect owner. The CMS manual gives the arithmetic: an indirect interest is the product of the percentages, so 10 percent of a company that owns 80 percent is an 8 percent indirect interest and must be reported. Every individual listed with 5 percent or more ownership will also be fingerprinted at initial enrollment; see high-risk screening.

Section 7: insurance and the surety bond

7A records comprehensive liability insurance of at least $300,000. "The contractor, with full mailing address, must be listed on the policy as a certificate holder," and "Professional and malpractice insurance is not the same as comprehensive liability insurance." 7B records the surety company, bond amount, number and effective date, with "a copy of the original surety bond, signed by a Delegated or Authorized Official." 7C is for exceptions: government-operated suppliers with a comparable state bond, Indian Health Service facilities, physicians furnishing to their own patients, solely owned PT or OT practices billing only orthotics, prosthetics and supplies, and solely owned custom O&P practices. More in the DMEPOS surety bond.

Do sections 8 through 11 matter?

Section 8 is for a billing agency, if you use one, and its address cannot double as your correspondence address. Sections 9, 10 and 11 are intentionally left blank on the current form.

Section 12: the attachment list

For new applications and new locations the mandatory documents are: copies of all federal, state and local licenses, certifications and registrations for your supplier type, products and services; the certificate of liability insurance naming your enrollment contractor; IRS confirmation of TIN and legal name where applicable; the CMS-588 with a voided check; and the receipt for the application fee. Conditional documents include the IRS determination letter for nonprofits, adverse action records, a bank's waiver of offset if you have a loan with the bank receiving payments, the delegated official's W-2, a bill of sale if you bought an enrolled supplier, the CMS-460 participation agreement if you want to be a participating supplier, the surety bond, and subcontracts. A notarized Certificate of Good Standing from the state board, no more than 30 days old, can stand in for license copies.

Section 13: can a consultant be the contact person?

Yes. Section 13 is optional and lets you name any person the contractor should call about the application, with their relationship to the supplier. The form limits that person's role: the contact person "will only be authorized to discuss issues concerning this enrollment application." We are usually listed here, which is how development requests reach us quickly.

Sections 14 and 15: penalties and the certification

Section 14 sets out the penalties for false statements, including 18 U.S.C. 1001, under which individuals face fines of up to $250,000 and imprisonment for up to five years. Section 15 is the certification. "Only an Authorized Official has the authority to sign (1) the initial enrollment application on behalf of the supplier and (2) add or remove additional Authorized Officials and Delegated Officials." A delegated official must have an ownership or control interest or be a W-2 managing employee, and "Delegated Officials may not delegate their authority to any other individual." On paper, "All signatures must be original and in ink," and "Signatures must be less than 120 days old at the time of submission." The regulation behind it is 42 CFR 424.510(d)(3).

That is why no outside firm can sign for you. We prepare every section, assemble section 12, and, once your authorized official approves White Glove Medical as a surrogate in the CMS Identity & Access system, enter and submit the application in PECOS. Your authorized official reviews it and signs the certification. See PECOS surrogate access.

Where do 855S files usually go wrong?

A legal name or TIN that does not match the IRS letter or NPPES.
Products checked in 2E4 that the accreditation does not cover.
States checked in 2D with no license attached where the state requires one.
An insurance certificate that does not name the enrollment contractor, or a professional liability policy offered as comprehensive liability.
Hours that do not total 30 a week, or "By Appointment Only" without a qualifying exception.
An indirect owner left off section 6.

Our Medicare DMEPOS Enrollment Package is $1,295 for the first location and $595 for each additional location; the $750 CMS fee for 2026 and the bond premium are paid by you directly. The enrollment hub shows where the 855S sits in the full sequence.