DMEPOS Enrollment, Step by Step, in the Order CMS Requires

Medicare enrollment for a durable medical equipment supplier is not one application. It is a sequence, and the order is set by the rules rather than by preference. The National Provider Enrollment contractors (NPEAST and NPWEST) process the CMS-855S, but CMS's own fact sheet says they "won't process any enrollment application unless the applicant is accredited or exempt" (MLN905710, December 2025). Accreditation, in turn, depends on state licenses and a working location. So a supplier that starts with the 855S usually ends up starting over.

Here is the order we work in, with the regulation or CMS document behind each step.

What has to exist before anything is filed?

Start with the business itself. The 855S asks for the legal business name exactly as reported to the IRS, the tax identification number, and an NPI for each location. The form says plainly that "each business location MUST have its own NPI, unless enrolling as a sole proprietor/proprietorship with multiple locations," and that the name, TIN and NPI must match exactly between PECOS and NPPES. A mismatch between the IRS letter (Form CP-575 or similar), the NPI record and the application is one of the simplest ways to earn a development request.

Ownership needs to be settled too. Section 6 of the 855S requires every person with a 5 percent or greater direct or indirect ownership interest, every officer and director of a corporation, every managing employee and every partner. The supplier must have at least one owner, one managing employee and one authorized official on the form.

Which state licenses come first?

The first supplier standard requires a DMEPOS supplier to operate in compliance with state licensure requirements: "If a State requires licensure to furnish certain items or services, a DMEPOS supplier ... Must be licensed to provide the item or service" (42 CFR 424.57(c)(1)(ii)). Section 2D of the 855S asks you to list every state where you provide items from the location and to "submit all required licenses for the products and services being provided" for each one.

The accrediting organization checks licensure as well. CMS describes the accreditation application stage as one where the organization "reviews your application and documentation (for example, verifies organizational chart and licensure)." That is the practical reason licenses sit at the front of the line. Requirements differ by state and often by product; the state DME license requirements page tracks what we have verified, and our post on licensing as an out-of-state supplier covers shipping to patients in other states.

Does the location meet the supplier standards yet?

A site that fails the standards fails the site visit, so build it right before you apply. The core physical requirements in 42 CFR 424.57(c) are:

• A practice location of at least 200 square feet, accessible to the public and to CMS, not in a gated community, staffed during posted hours, with a permanent visible sign and posted hours (standard 7). Custom O&P personnel in private practice have an exception to the square footage rule.
• A primary business telephone at the site, listed under the business name. A cell phone, pager or answering service cannot be the primary line, and calls cannot be forwarded exclusively to a cell phone (standard 9).
• Open to the public at least 30 hours a week, with exceptions for physicians and PT or OT practices furnishing items to their own patients and for custom O&P (standard 30).
• Comprehensive liability insurance of at least $300,000 covering the place of business, customers and employees (standard 10). The 855S adds that your enrollment contractor must be listed as a certificate holder, and that professional or malpractice coverage does not satisfy the requirement.
• No shared practice location with another Medicare provider or supplier, apart from narrow exceptions (standard 29).

The full list is in our plain-English walk through the 30 supplier standards.

When does accreditation happen?

Before the 855S, for every supplier that is not exempt. MLN905710 states: "Except for exempted suppliers listed in the table, you must have DMEPOS supplier-accredited status before submitting your Medicare enrollment application." The CMS Program Integrity Manual tells the contractor to deny an application if the package "does not contain an approved accreditation upon receipt" (chapter 10, section 10.2.5.1).

Accreditation runs in three stages: choosing and working with an accrediting organization, the application, and an unannounced on-site survey. The accreditation must name the specific products and services you will bill (424.57(c)(22)(ii)), so the product list on the 855S and the scope of your accreditation have to line up. From January 1, 2026, accredited suppliers are resurveyed and reaccredited at least once every 12 months (424.57(c)(24)). See why accreditation comes before the 855S and choosing an accrediting organization.

Why does the bond come after accreditation?

Strictly, it does not have to, but the timing matters. The base bond is $50,000 for each assigned NPI, from a surety holding a Treasury Certificate of Authority, and "the term of the initial surety bond must be effective on the date that the application is submitted" (424.57(d)(2)(i)). The contractor adds $50,000 for each adverse legal action in the 10 years before enrollment (424.57(d)(3)(ii)). Buying the bond months before you can apply pays premium on a bond you cannot use yet. Our post on the DMEPOS surety bond explains the amounts and exceptions.

How is the application fee paid?

For applications submitted in calendar 2026 the fee is $750 (CMS-6096-N, 90 FR 55738). The 855S tells suppliers to pay it through PECOS "PRIOR to completing and submitting this application," and the receipt is part of the required documentation. A supplier with a genuine hardship can submit a hardship exception request with the application instead (42 CFR 424.514). Details are in the 2026 application fee and the hardship exception.

Who prepares, submits and signs the 855S?

The application can go in on paper or through PECOS. Section 12 of the 855S lists the mandatory attachments for a new supplier: licenses for each state and product, the certificate of liability insurance, the IRS confirmation of your TIN and legal name, the CMS-588 electronic funds transfer agreement with a voided check, the fee receipt and, where they apply, the surety bond, contracts, bill of sale and adverse action documents.

Only the supplier can sign it. The certification "must be signed by an individual who has the authority to bind the provider or supplier, both legally and financially," with an ownership or control interest (42 CFR 424.510(d)(3)), and the 855S says "Only an Authorized Official has the authority to sign (1) the initial enrollment application." A consultant can prepare the application and, once your authorized official approves the connection in the CMS Identity & Access system, enter and submit it in PECOS as a surrogate. CMS's I&A FAQ is explicit that "Surrogates may not sign, electronically or otherwise, any application on behalf of another individual." Our post on PECOS surrogate access walks through the connection.

What happens after submission?

1. Screening. Newly enrolling DMEPOS suppliers are in the "high" risk category (424.518(c)(1)(ii)). That means license and database checks, an on-site visit, and fingerprints from every individual with a 5 percent or greater direct or indirect ownership interest for an FBI criminal history check. See high-risk screening and fingerprints.
2. The site visit. The 855S says the contractor "conducts a site visit to verify compliance with the supplier standards." The manual tells the contractor not to approve a high-risk enrollment before the site visit is complete and reviewed. Prepare with our site visit checklist.
3. Development requests. The contractor may ask for more documentation, and the 855S says you have 30 days to provide it (citing 42 CFR 424.525(a)(1)). A missed deadline can mean a rejected application.
4. The decision. The contractor notifies you in writing. "Billing privileges are not effective until the contractor assigns your Medicare Identification Number" (the PTAN), and Medicare pays only for items furnished on or after the date CMS issued the supplier number (424.57(b)(2)).

No one controls the contractor's timeline, and nobody honest will promise a date. What a supplier controls is sending a complete, consistent file the first time.

Is a moratorium still something to check?

Yes. On February 27, 2026, CMS imposed a nationwide six-month moratorium on new Medicare enrollments, including new practice locations, for seven "medical supply company" supplier types (CMS-6099-N, 91 FR 9855). Pharmacies and other supplier types were not covered. The competitive bidding contractor's licensure page said that, as of June 4, 2026, CMS had not decided whether to extend it, and trade sources report it expired August 27, 2026. CMS can impose moratoria in six-month blocks and extend them (42 CFR 424.570(b)), so confirm the current status in the Federal Register before you file. Our post on the 2026 moratorium has the details.

Where does enrollment end and the rest begin?

A PTAN is the start of ongoing obligations: report changes within 30 days (the 30-day rule), keep the bond and insurance continuous, pass an accreditation resurvey every 12 months, and revalidate every three years (revalidation). Medicaid and commercial networks come on top; see Medicaid DME enrollment and commercial DME networks. Commercial and Medicaid managed care payer applications are handled by our sister company, White Glove Credentialing, whose post on getting on insurance panels covers that side.

How do we help, and what does it cost?

We start with a DMEPOS Readiness Review for $149, credited toward a package: a check of your licenses, location, insurance, accreditation scope and ownership disclosures against the rules above. The Medicare DMEPOS Enrollment Package is $1,295 for the first location and $595 for each additional location. Accreditation Readiness, which covers the policy manual, file setup and a mock survey, is $2,495. We prepare every document and, as your approved PECOS surrogate, submit the 855S; your authorized official signs the certification. We never hold your I&A login or PIN. CMS, accreditation, bond and fingerprint fees are paid by you directly. The DMEPOS enrollment hub has the full sequence on one page.