Medicare Enrollment for Organizations & Group Practices

Organizations and group practices have a layered Medicare enrollment structure. It’s not just one form — it’s the organization’s enrollment, each provider’s individual enrollment, and the reassignment links that make group billing possible.

This page provides the overview. Each component has its own detailed guide.

The organization enrollment structure

1. Organization enrolls (CMS-855B or CMS-855A)
   → Gets organizational PTAN and Type 2 NPI billing privileges
   
2. Each individual provider enrolls (CMS-855I)
   → Gets individual PTAN and individual billing privileges

3. Each provider reassigns (CMS-855R)
   → Links individual provider to organization
   → Enables organization to bill under group NPI for that provider's services
   
4. Organization sets up EFT (CMS-588)
   → Medicare payments go directly to organization's bank account

All four components must be in place before the organization can bill Medicare for a provider’s services.

Which form does your organization need?

The ownership disclosure requirement

This is where many organizations run into problems. The CMS-855B requires comprehensive disclosure of:

• All owners with 5% or more ownership interest (direct and indirect)
• All managing employees (individuals with operational or financial control)
• All related organizations (entities with common ownership)

“Managing employee” is broader than “senior management.” It includes anyone with authority over financial decisions, hiring, or compliance — regardless of their title.

⚠️ Incomplete ownership disclosure is a basis for denial and potential OIG referral. When in doubt, disclose.

For organizations with complex ownership structures (private equity-backed practices, multi-location chains, hospital-owned outpatient practices): get legal review of your ownership disclosure before filing.

Multi-location organizations

If your organization operates at multiple physical locations:

• Each location should be listed in the CMS-855B enrollment
• All locations operate under the same organizational PTAN and Type 2 NPI (for a single legal entity)
• If different locations are different legal entities (different EINs), each entity needs its own CMS-855B enrollment

For hospital-owned outpatient practices claiming provider-based billing status:

• This requires a separate provider-based attestation/notification to CMS
• Provider-based billing has specific documentation and cost-reporting requirements
• This is not the same as standard group practice enrollment

Adding new providers to an enrolled organization

When a new provider joins an enrolled organization:

1. Provider files CMS-855I (individual enrollment) — or confirm existing enrollment is active
2. Provider files CMS-855R (reassignment to organization)
3. Wait for MAC processing (~30–60 days)
4. Once the reassignment is approved, the organization can bill under its NPI for that provider’s services

⚠️ Don’t submit claims under the group NPI for a provider whose reassignment isn’t yet approved. Claims will be denied.

Provider departure: terminating reassignment

When a provider leaves:

1. File a CMS-855R termination (provider or organization can file)
2. Specify the termination effective date
3. After that date, the organization cannot bill for the provider’s services
4. Provider’s individual enrollment remains intact — they can join another organization or bill independently

File the termination promptly. Continued billing after departure and before termination creates compliance exposure.

Related pages

• CMS-855B — Organization & Group Practice Enrollment
• CMS-855A — Institutional Provider Enrollment
• CMS-855R — Reassignment of Medicare Benefits
• Group Practice Medicare Enrollment (detailed guide)
• Reassignment of Medicare Benefits (detailed guide)
• FQHC and RHC Medicare Designation
• NPI for Group Practices

Questions about your organization’s Medicare enrollment structure? Ask Mae → Free Metolius Health enrollment audit →