DMEPOS suppliers must report every change to their Medicare enrollment information within 30 days under supplier standard 2, from a new suite or phone number to owners, officials, insurance, bond and accreditation. Late reports can mean deactivation or revocation backdated to the day after the deadline, and some changes require a new enrollment.
Most Medicare providers have 30 days to report some changes and 90 days for the rest (42 CFR 424.516(e)). DMEPOS suppliers do not get the 90. Supplier standard 2 says: "The supplier must report to CMS any changes in information supplied on the application within 30 days of the change" (42 CFR 424.57(c)(2)). The CMS-855S repeats it, and CMS's fact sheet puts it plainly: "To avoid having your Medicare billing privileges revoked, report any change within 30 days" (MLN905710, December 2025).
What counts as a change?
Anything you reported on the 855S. Section 1B of the form lists the categories, and each one names the sections you complete:
- business location, including a move to a different suite
- supplier type, with licenses
- products and services, with accreditation
- accreditation information
- any of the mailing, correspondence, revalidation, payment or records addresses
- comprehensive liability insurance
- surety bond
- final adverse legal actions
- ownership and managing control, organizations or individuals
- billing agency
- authorized and delegated officials
- "Any other information not specified above," which includes hours of operation and phone numbers
MLN905710 singles out change in ownership, adverse legal action, change in practice location and accreditation changes. A new state license added to cover patients in another state is also a change; see getting your state licenses into PECOS.
Which changes are really new enrollments?
A few changes cannot be handled as an update:
- A new location is a separate enrollment with its own 855S, NPI, bond coverage, fee and accreditation survey.
- A new TIN requires "a new CMS-855S enrollment application in its entirety," and CMS's accreditation Q&A says a supplier changing its TIN "must be surveyed and accredited and enroll in the Medicare program as a new DMEPOS supplier."
- A change in majority ownership within 36 months of enrollment or the last majority change means the buyer enrolls as a new supplier with new accreditation (42 CFR 424.551). See the 36-month rule.
Who can sign a change of information?
An authorized official, or a delegated official once one has been properly designated. Under 42 CFR 424.510(d)(3)(ii), "Any updates or changes reported outside of the initial enrollment or periodic revalidation process may be signed by a delegated official." The delegated official must have an ownership or control interest or be a W-2 managing employee, and must be assigned by the authorized official. Designating a delegated official is worth doing for any supplier whose owner is not in the office every day.
Which changes also go to the accrediting organization?
Several, and the clock is the same. CMS's DMEPOS accreditation guidance says suppliers "must notify their AO within 30 days of the effective date of any change of ownership" and "within 30 days of a change of location/relocation," and that the accrediting organization will survey a relocated site before accreditation is issued. New locations and new product lines require notice so they can be surveyed (424.57(c)(23) and (25)). The enrollment contractors and accreditors are independent, so telling one does not tell the other.
What happens when a change is reported late?
CMS may revoke for "Failure to report" under 42 CFR 424.535(a)(9), weighing whether the data was reported, how late, and how material it was. The effective date is the problem: for failing to timely report a change of ownership, an adverse legal action, or a change, addition or deletion of a practice location, the revocation takes effect "the day after the date by which the provider or supplier was required to report" (424.535(g)). Claims paid after that date are at risk. CMS may also deactivate billing privileges for an unreported change (424.540(a)(2)), and Medicare does not pay for items furnished while deactivated.
A move is the classic case. If the site visitor goes to the old address and finds it empty, the manual tells the contractor to revoke as non-operational unless you had already submitted a change of information reporting the new location.
Do changes trigger screening?
Some do. Reporting any new owner, regardless of percentage, puts a DMEPOS supplier in the "high" screening category (42 CFR 424.518(c)(1)(vii)), which means fingerprints for 5 percent owners. A change of location, including a suite or floor change, requires a site visit. See high-risk screening.
How do we keep suppliers inside the 30 days?
A Change of Information is $249 (see pricing). We prepare the 855S sections the change requires, notify your accrediting organization where needed, and submit through PECOS as your approved surrogate; your authorized or delegated official signs. Most suppliers who get caught by the 30-day rule were not unaware of it; they simply learned about the change from a landlord, a bank or an insurer too late. Ask us before you sign a new lease, change insurers or add an owner.
Common questions
- How long do DME suppliers have to report changes to Medicare?
- 30 days for every change, under 42 CFR 424.57(c)(2). Other provider types get 90 days for some changes, but DMEPOS suppliers do not.
- Does changing my business hours count as a change of information?
- Yes. Hours are reported in section 2A of the 855S, and the form treats any information not otherwise listed as a reportable change. Hours also must stay at 30 a week unless an exception applies.
- Who can sign a DMEPOS change of information?
- The authorized official, or a delegated official the authorized official has designated. A delegated official must be an owner or a W-2 managing employee.
- What happens if I report a move late?
- CMS can revoke billing privileges effective the day after the reporting deadline, and a site visit to the old address can be treated as a non-operational location.
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