The CMS-2728 is not a provider enrollment form. It’s the Medical Evidence Report used to document the medical basis for a patient’s End-Stage Renal Disease (ESRD) Medicare eligibility determination.

Patients with ESRD are eligible for Medicare regardless of age — one of Medicare’s three eligibility categories (along with age 65+ and disability). The CMS-2728 is the clinical documentation that establishes that eligibility. Providers who treat ESRD patients — nephrologists, dialysis facilities, and transplant centers — are responsible for completing it.

This page is here because providers who care for ESRD patients encounter the CMS-2728 as part of the Medicare billing and enrollment workflow, and many have questions about what it requires and who’s responsible for it.

What the CMS-2728 documents

The CMS-2728 captures:

Clinical information establishing ESRD diagnosis — lab values (BUN, creatinine, GFR), clinical findings, diagnosis codes
Date ESRD treatment began — this determines the Medicare effective date
Type of treatment initiated — hemodialysis, peritoneal dialysis, or kidney transplant
Provider information — the physician and dialysis facility or transplant center involved in care
Patient information — demographics, Social Security Number, insurance information

The form is submitted to the patient’s Medicare Administrative Contractor (MAC) to initiate the ESRD Medicare eligibility process.

Who completes the CMS-2728

The CMS-2728 is completed jointly:

The attending physician completes the clinical sections — diagnosis, lab values, treatment type, date treatment began, clinical notes.

The dialysis facility or transplant center completes the facility sections — facility name, Medicare provider number, facility contact information.

For most ESRD cases, the nephrologist and the dialysis facility coordinate to complete and submit the form. The dialysis facility typically takes administrative responsibility for submission.

When the CMS-2728 must be filed

The CMS-2728 must be filed within 90 days of the initiation of ESRD treatment (dialysis or transplant). Filing within this window:

Ensures the patient’s Medicare effective date is correctly established
Allows Medicare to coordinate with other insurers (if the patient has other coverage)
Activates Medicare coverage for dialysis and related services

⚠️ Late filing has consequences. If the CMS-2728 is filed more than 90 days after treatment begins, CMS may not be able to establish the earliest possible Medicare effective date. This can result in coverage gaps and billing complications.

ESRD Medicare coverage timeline

ESRD Medicare coverage typically begins:

For dialysis patients: The first day of the fourth month after the month dialysis begins (there’s a 3-month waiting period for most dialysis patients, unless they meet criteria for a shorter waiting period)
For self-dialysis training patients: The first day of the month in which training begins
For transplant patients: The month the transplant occurs, or the month of hospital admission for the transplant (whichever is earlier)

Exceptions to the waiting period exist for patients who participate in a self-care dialysis training program — your MAC can clarify the specific rules.

Step-by-step: Completing the CMS-2728

Step 1: Gather clinical documentation

Most recent nephrology evaluation notes
Lab values: serum creatinine, BUN, GFR
Diagnosis code(s) for ESRD and underlying cause
Date dialysis or transplant began

Step 2: Complete the physician section The attending nephrologist or treating physician completes:

Clinical diagnosis and relevant laboratory findings
Type of treatment (in-center hemodialysis, peritoneal dialysis, home hemodialysis, transplant)
Date regular dialysis began
Physician NPI and signature

Step 3: Complete the facility section The dialysis facility or transplant center completes:

Facility name and Medicare provider number
Facility address and contact information
Facility administrator or authorized official signature

Step 4: Submit to the MAC Submit to the beneficiary’s MAC. The dialysis facility typically handles submission as part of their patient intake/enrollment process.

Step 5: Obtain confirmation The MAC will confirm receipt and process the ESRD eligibility determination. Retain a copy of the submitted form in the patient record.

⚠️ Risk flags

⚠️ Incorrect treatment start date. The date treatment began determines the Medicare effective date. An incorrect date on the CMS-2728 can shift the effective date, creating billing gaps or overpayment situations.

⚠️ Missing physician signature. The form requires the treating physician’s signature. Unsigned forms are returned for completion.

⚠️ Transplant vs. dialysis routing. Patients who receive kidney transplants have different Medicare coverage triggers than dialysis patients. Transplant centers have specific responsibilities for CMS-2728 completion and submission.

⚠️ Coordination with patient’s other insurance. If an ESRD patient has employer group health coverage, Medicare coordination of benefits rules apply. The CMS-2728 initiates the process, but the patient’s full insurance picture should be documented at the same time.

Provider enrollment note

The CMS-2728 is not a provider enrollment form — it doesn’t give you Medicare billing privileges. If you are a nephrologist, dialysis facility, or transplant center that isn’t yet enrolled in Medicare as a provider:

Individual nephrologists: CMS-855I
Dialysis facilities and transplant centers: CMS-855A

Questions about ESRD enrollment and the CMS-2728? Ask Mae →