Medicare provider enrollment enables healthcare providers to register with the Centers for Medicare & Medicaid Services (CMS) so they can receive reimbursement for services provided to Medicare beneficiaries. This process involves submitting applications and documentation to verify compliance with CMS regulations and standards. 

As CMS continues to roll out new rules with increased enforcement activity, staying ahead of the latest updates is crucial. This blog covers what you need to know in 2025, plus strategies to keep your enrollment and revalidation processes running smoothly. 
 

Overview of Medicare & Medicaid Provider Enrollment 

Medicare provider enrollment is required for any provider or supplier that wants to bill Medicare for services. The application process, typically through the Provider Enrollment, Chain, and Ownership System (PECOS), verifies that you meet CMS qualification and participation standards. 

Medicaid enrollment, while state-specific, often overlaps with CMS requirements, meaning that accurate, up-to-date enrollment data benefits you across multiple programs. 
 

Recent Updates in Provider Enrollment Policies 

CMS continues to refine enrollment rules to increase transparency and reduce fraud risk.

Continued Expansion of the 36-Month Rule

Originally designed for home health agencies and expanded to hospice providers in 2024, the 36-Month Rule now applies to certain high-volume, high-risk provider types. The intent remains the same: to prevent rapid changes of ownership that could bypass standard compliance reviews. 

Updated CMS Form 855 Series

CMS has rolled out further updates to the 855 forms, including:

• Streamlined sections for telehealth-focused providers 
• New disclosure fields for ownership and managing control relationships 
• Broader e-signature acceptance and integration with PECOS for faster processing

Enhanced Screening for High-Risk Providers

High-risk categories, such as new hospices, DMEPOS suppliers, and opioid treatment programs, continue to face more rigorous background checks. These can include fingerprinting of all individuals with a 5% or greater ownership stake.

Heightened Enrollment Compliance Audits

CMS has increased post-enrollment site visits, particularly for providers with recent changes in ownership or location. Unannounced inspections and verification of operational capacity are becoming more common.

Updating Your CMS-855 Enrollment Information 

Keeping your CMS-855 data accurate is not optional; it’s a regulatory requirement.  

• 90-Day Rule: Most changes must be reported within 90 days of the effective date. 
• 30-Day Rule: Certain changes (including change of ownership, adverse legal actions, or changes to a practice location) must be reported within 30 days.

Failing to meet these deadlines can result in payment delays, deactivation, or even revocation of billing privileges. 

What are the best practices for 2025 Medicare provider enrollment? 

To stay compliant and avoid costly enrollment issues: 

• Monitor policy updates: CMS releases changes year-round, not just at year-end. 
• Centralize your enrollment data: Keep ownership, location, and licensure details in a single, accessible place. 
• Assign a compliance lead: Designate someone to track revalidation cycles and policy changes. 
• Leverage PECOS efficiencies: Online submission often shortens processing times. 
• Prepare for site visits: Maintain updated operational and staffing records in case of an unannounced inspection. 
  

Navigate Enrollment with Lutz 

At Lutz, we work with healthcare organizations to simplify Medicare and Medicaid enrollment, reduce processing delays, and maintain compliance with evolving CMS rules. Whether you’re enrolling for the first time, revalidating, or managing a change of ownership, our healthcare experts can guide you through each step. Contact us to learn more.