The 2026 Medicare Application Fee and the Hardship Exception

Medicare charges an application fee to "institutional providers," and every DMEPOS supplier filing a CMS-855S is one. The definition in 42 CFR 424.502 names the 855S expressly. For applications submitted from January 1 through December 31, 2026, the fee is $750 (CMS-6096-N, published December 3, 2025, 90 FR 55738).

How did CMS arrive at $750?

The statute set a $500 fee for 2010, and each year since CMS adjusts the prior year's fee by the change in the consumer price index for all urban consumers over the 12 months ending June 30 (42 CFR 424.514(d)(2)). The 2025 fee was $730. CPI-U rose 2.7 percent from July 2024 through June 2025, so CMS calculated $730 times 1.027, or $749.71, and rounded to $750.

CMS estimated that about 12,518 newly enrolling and 33,863 revalidating institutional providers would pay the Medicare fee in 2026. Those figures cover every institutional provider type, not only DME suppliers.

Which DME applications need the fee?

Three kinds, per 424.514 and the CMS-6096-N notice:

• An initial enrollment.
• A new practice location. Each DMEPOS location is enrolled separately, so the CMS Program Integrity Manual says "The enrollment of each site thus requires a separate fee."
• A revalidation. This includes a reactivation after a supplier was deactivated for not responding to a revalidation request, because the manual treats that resubmission as a revalidation.

The manual lists DMEPOS transactions that do not need a fee: a change of ownership reported on the 855S, a change in TIN, moving an existing location to a new address, and most other changes of information. A physician or practitioner group enrolling as a DME supplier on the 855S does pay it, even though the same group pays no fee on its 855I or 855B.

When and how is it paid?

Before you submit. The 855S says the supplier "pays the required application fee ... PRIOR to completing and submitting this application," and "the application fee must be paid in the calendar year you are submitting the CMS-855S application." Payment is electronic through the PECOS fee page, by credit card, debit card or electronic check; a paper check sent with a paper application is voided and returned. The receipt is one of the mandatory attachments in section 12. For PECOS applications, the manual says PECOS will not accept the application without the fee or a hardship request.

The year matters. If you pay a 2026 fee but the application is submitted or postmarked in 2027, you owe the 2027 amount, and the manual says CMS will not consider a hardship exception in that situation.

What if the fee is missing?

For a paper application, the contractor sends a letter giving 30 days to pay through Pay.gov. Failure leads to rejection of an initial or new-location application, or revocation for a revalidation (424.514(g) and 424.535(a)(6)). A check that bounces is its own problem: a contractor may deny or revoke if the account "does not contain sufficient funds to pay the application fee" (424.514(e)).

When is the fee refunded?

The fee "is nonrefundable" except in three cases listed in 424.514(d)(2)(v): an approved hardship exception, an application rejected before screening began, and an application denied because a temporary moratorium was imposed. That third case mattered in 2026, when CMS imposed a nationwide moratorium on new medical supply company enrollments (CMS-6099-N; see the 2026 moratorium). The manual also refunds a fee paid for a transaction that did not need one. Refund requests generally must be made within 150 days of submitting the application.

What does a hardship exception request need?

The request is a letter submitted with the application that "describes the hardship and why the hardship justifies an exception" (424.514(f)). A letter sent separately from the application is returned unconsidered. The manual is blunt about the standard: "The application fee generally should not represent a significant burden for an adequately capitalized provider," and an exception should not be granted when a provider "simply asserts" financial hardship. It expects comprehensive documentation such as cost reports, balance sheets, income statements, cash flow statements and tax returns. Factors that may support an exception include:

• considerable bad debt expense;
• a significant amount of charity care or financial assistance;
• substantive partnerships with those serving a disproportionately low-income population;
• enrolling in an area that is a Presidentially declared disaster under the Stafford Act (424.514(c)).

CMS has 60 days to decide, and the contractor does not begin processing the application while the request is pending (424.514(h)). If CMS denies it, you have 30 days from the notice to pay; otherwise an initial application is denied under 424.530(a)(9). A denial can be appealed by a written reconsideration request within 60 calendar days, signed by the supplier, a legal representative or an authorized official.

For a new DME company with startup losses, a hardship request is rarely worth the delay. The fee is small next to the bond, insurance and accreditation costs, and a pending request stops the clock.

Who pays the fee when we prepare the application?

You do, directly to CMS, as with every government, accreditation, bond and fingerprint fee. Our Medicare DMEPOS Enrollment Package is $1,295 for the first location and $595 for each added location, Medicare Revalidation is $595, and none of those include the CMS fee. We tell you when to pay so the receipt matches the calendar year of submission. See DMEPOS enrollment step by step for where the fee falls in the sequence.