Getting Your State Licenses Into PECOS

Medicare checks state licensing through your enrollment record, not through the states. The CMS-855S asks each business location to list the states where it furnishes items and to "submit all required licenses for the products and services being provided" for each one (Section 2D, form version 12/23). CMS then uses PECOS to check: for Round 2028 competitive bidding, CBIC says "CMS will verify your licenses through PECOS," location by location. A license that sits in a drawer, expired on the record or missing from it, can cost a bid or an enrollment just as surely as one you never obtained.

Where do licenses go on the CMS-855S?

Two places:

• Section 2D, States Where Items Are Provided. "Select all State(s)/Territory(ies) where you provide items or services to Medicare beneficiaries from the business location in Section 2A. For each State/Territory selected, submit all required licenses for the products and services being provided." The form adds that the contractors' websites "may offer guidance on licensure requirements."
• Section 2E4, Products and Services. "Check all that apply and submit all applicable licenses and/or certifications." If you fill orders, fabricate or fit items by contracting with other companies, the form asks for those contracts too.

Because each location enrolls separately ("CMS issues only one supplier number for each location," 42 CFR 424.57(b)(2)), the state list and the licenses are per location as well. A national supplier with three locations has three state lists, and the licenses under each must match the states that location actually serves.

What if a state has no license for what I supply?

Then there is nothing to attach for that state, but you should know that for a fact, not assume it. Texas, for example, has no general DME supplier license (25 Tex. Admin. Code 229.433, 229.434), while Pennsylvania, often described as having none, requires a Department of Health registration for anyone retailing devices (28 Pa. Code 25.113). A product license, such as an oxygen permit or an O&P practitioner license, can apply where a general license does not. CBIC warns that the contractors' "DMEPOS Licensure Database Directory" is "a guide only," adding that "licensing rules can change, and it is your responsibility to ensure your licenses are current and reflected in PECOS." See DME license requirements by state.

Can I add a new license or state later?

Through a change of information. The supplier standards require a supplier to "report to CMS any changes in information supplied on the application within 30 days" (42 CFR 424.57(c)(2)). The 855S lists the sections to complete for each kind of change; changes to supplier type or products and services call for submitting the relevant licensure. A change of business location "requires submission of professional and business licenses for the new address, and proof of insurance covering the new address."

Renewals count too. When a state issues a renewed license with a new expiration date, the record should show the current one. CBIC's rule is that licenses must be "current and non-expired in PECOS." See the 30-day rule for reporting changes.

How does competitive bidding raise the stakes?

CBIC's Licensure for Bidders page for Round 2028 sets the standard:

1. "you must have all applicable state/territory licenses for every item in the product category you are bidding on ... by the close of the bid window," for each state, D.C. and territory "where you would furnish competitively bid DMEPOS items."
2. A bidder need not hold a license everywhere before submitting a bid, "but all required licenses must be current and non-expired in" PECOS "by the close of the bid window."
3. Licenses must stay current "throughout the bid evaluation process, and, if awarded a DMEPOS CBP Contract, through the entire DMEPOS CBP contract performance period."
4. "All locations collectively on your bid must meet all applicable licensing requirements for every item in the product category. If a State/Territory requires a specific license, the bidder must ensure at least one of its locations meets the applicable requirements."

For Round 2028's single nationwide remote item delivery area, which CBIC says "includes all states, territories, and the District of Columbia," that means every state's rules matter for a bidder in the remote delivery categories. On October 7, 2026 CMS set bidder registration to open December 1, 2026 and the bid window to open January 5, 2027. See the bid window licensing deadline and the nationwide remote item delivery area.

Which location should hold which license?

For a multi-location supplier this is a planning question, and the answer shapes cost. CBIC allows the licensing requirement to be met collectively by the locations on a bid, and after award a supplier can add a location through a change of location request; "A location would be eligible to be added to a contract if the location is licensed in one applicable State, District of Columbia, or any U.S. Territory in the RID CBA." State rules push the other way in places: Alabama ties out-of-state branches to a licensed Alabama location (Ala. Admin. Code 473-X-3-.02), and Georgia, North Carolina and others license each place separately. Map states to locations before filing, so each license lands on the location the state actually licensed.

Which mistakes are most common?

• A license on the wrong location. The state licensed location B, but location A lists the state.
• An expired copy. The state renewed, but PECOS still shows last year's certificate.
• A state served but not listed. Shipping into a state not selected in Section 2D for that location.
• A product added without its license. A new oxygen or prescription device line that needs a permit the location never obtained.
• A move. A relocation reported without the new address's licenses and insurance.

CMS's fact sheet (MLN905710) is blunt about the risk: if a supplier violates a standard, "like not being appropriately licensed," the enrollment contractors "may deny enrollment or revoke Medicare billing privileges."

Who signs, and who submits?

Your authorized official signs the 855S certification, which "must be signed by an individual who has the authority to bind the provider or supplier, both legally and financially" (42 CFR 424.510(d)(3)). Once your authorized official approves White Glove Medical as a surrogate in CMS's Identity & Access system, we can enter license updates and submit the change in PECOS; we never hold your login or e-signature PIN. See PECOS surrogate access.

How much does the PECOS license work cost?

A Change of Information is $249; License Renewal Tracking, which includes keeping the renewed license current on your record, is $299 per license, per year. For bidders, the Remote Delivery Licensing Package covers 10 states for $4,995 and the Nationwide Licensing Package is $9,995 (pricing). State fees are paid by you directly. More on the enrollment side at DMEPOS enrollment.