CMS-855A: Institutional Provider Enrollment

The CMS-855A is the Medicare enrollment application for institutional providers. If your organization is a hospital, skilled nursing facility, home health agency, hospice, comprehensive outpatient rehabilitation facility (CORF), or certain other facility types, the CMS-855A is your enrollment form.

Institutional enrollment is significantly more complex than individual or group practice enrollment. The CMS-855A is longer, requires more supporting documentation, and involves additional steps including state survey and certification for certain provider types.

Who files the CMS-855A

Provider types enrolled via CMS-855A:

• General acute care hospitals
• Critical access hospitals (CAHs)
• Psychiatric hospitals and units
• Long-term acute care hospitals (LTACHs)
• Inpatient rehabilitation facilities (IRFs) and units
• Skilled nursing facilities (SNFs)
• Swing bed hospitals
• Home health agencies (HHAs)
• Hospices
• Comprehensive outpatient rehabilitation facilities (CORFs)
• Outpatient physical therapy (OPT) providers / outpatient occupational therapy providers
• Portable X-ray suppliers
• End-stage renal disease (ESRD) facilities (dialysis centers)
• Rural health clinics (RHCs) — see also FQHC and RHC guide
• Federally qualified health centers (FQHCs)

If you’re a physician group practice or non-institutional clinic: use the CMS-855B. If you’re a DMEPOS supplier: use the CMS-855S.

State survey and certification: the prerequisite for most institutional providers

Most institutional providers — hospitals, SNFs, HHAs, hospices, dialysis facilities — must be certified by the state survey agency before Medicare enrollment can proceed. This is separate from (and precedes) the CMS-855A filing.

Certification involves:

1. State survey agency inspection of your facility
2. Verification that you meet Medicare Conditions of Participation (CoPs) or Conditions for Coverage (CfCs)
3. State survey agency recommendation to CMS for certification
4. CMS issuance of Medicare Certification Letter

This process typically takes 6–18 months for new facilities. The CMS-855A cannot be approved until certification is in place.

Important: Don’t let the certification timeline surprise you. Most healthcare lawyers and consultants will advise you to begin the survey/certification process 12–18 months before your planned opening date.

Before you file the CMS-855A

1. Complete state survey and certification (if applicable to your facility type)
2. Obtain Type 2 NPI for the institutional provider
3. Obtain state business license and operational permits
4. Secure physical facility that meets Medicare CoP/CfC requirements
5. Establish governing body and organizational structure
6. Obtain appropriate liability insurance
7. Set up Quality Reporting Program registration (if applicable)

Step-by-step: Filing the CMS-855A

Institutional enrollment is primarily a paper process. CMS has not fully extended PECOS to all institutional enrollment scenarios. Check with your MAC for current electronic filing options.

Step 1: Download the current CMS-855A From cms.gov. The form is lengthy — print and review in full before completing.

Step 2: Section 1 — Provider identification

• Legal business name
• “Doing business as” name
• EIN
• Provider type (hospital, SNF, HHA, etc.)
• Medicare certification number (if previously certified)
• NPI

Step 3: Section 2 — Addresses

• Physical location (no P.O. Boxes)
• Mailing/correspondence address
• Each service location

Step 4: Section 3 — Contact information Authorized official, contact person, billing agent (if applicable).

Step 5: Section 4 — Ownership and managing control Same comprehensive disclosure requirement as CMS-855B:

• All owners with 5%+ interest
• All managing employees
• All related organizations This section is audited carefully for institutional providers.

Step 6: Section 5 — Chain of ownership Critical for hospital systems, multi-facility SNF chains, national HHA organizations. Document the full ownership structure up to and including ultimate parent entities.

Step 7: Section 6 — Adverse legal history All adverse actions against the institution and its owners/managing employees.

Step 8: Section 7 — Type-specific sections CMS-855A has sections specific to certain facility types (e.g., swing bed notification for eligible hospitals, specific sections for ESRD facilities).

Step 9: Compile supporting documentation Typically required:

• CMS Certification Letter (or state survey certification)
• State operating license(s)
• IRS EIN documentation
• Articles of incorporation
• Accreditation survey report (if accreditation used for deemed status)
• Board authorization (evidence that the authorized official has authority to bind the organization)

Step 10: Authorized official signature Must be signed by an individual with legal authority to bind the institution (CEO, president, managing partner, etc.).

Step 11: Mail to MAC Submit to your jurisdiction’s MAC enrollment processing address.

Deemed status vs. state survey

Hospitals and other providers with accreditation from certain CMS-approved accrediting organizations (The Joint Commission, DNV Healthcare, HFAP) may qualify for “deemed status” — CMS accepts the accreditor’s survey in lieu of a separate state survey. Deemed status providers still file the CMS-855A; the difference is in the certification evidence submitted.

⚠️ Risk flags

⚠️ Ownership disclosure for multi-facility systems. Institutional providers in chains or systems must disclose the full ownership chain. CMS cross-references institutional ownership disclosures against program exclusion databases. Undisclosed related entities are a significant revocation risk.

⚠️ Conditions of Participation must be maintained post-enrollment. Initial certification is only the beginning. Failing a subsequent state survey or losing accreditation while enrolled can result in Medicare termination. Maintain your CoP/CfC compliance continuously.

⚠️ Change of ownership (CHOW) requires immediate notification. If ownership of the institution changes, CMS must be notified within 90 days. A CHOW may require a new CMS-855A filing. Failure to report a CHOW is a basis for revocation.

⚠️ Provider-based designation for off-campus departments. If you’re establishing an off-campus outpatient department that bills as provider-based (under the hospital’s Medicare number), the provider-based designation rules are separate from institutional enrollment and require specific CMS notification. This is a compliance area where many health systems have errors.

Processing timeline

Related pages

• CMS-855B — Organization & Group Practice Enrollment
• FQHC and RHC Medicare Designation
• Group Practice Medicare Enrollment
• Medicare Provider Revalidation

Questions about institutional enrollment, deemed status, or Conditions of Participation? Ask Mae → Free Metolius Health enrollment audit →