The Provider Enrollment, Chain, and Ownership System (PECOS) received several updates in late 2025 and early 2026 to accommodate new Medicare-eligible provider types and to streamline processing for existing ones.
New provider type support
CMS added PECOS enrollment pathways for provider types newly eligible under the Consolidated Appropriations Act and CY2026 rulemaking:
BCBAs and BCaBAs (ABA therapy)
- Taxonomy code 103K00000X (Behavioral Analyst) is now fully recognized in PECOS
- Individual BCBAs enroll using the CMS-855I pathway in PECOS
- Group ABA practices use CMS-855B; reassignment via CMS-855R
- PECOS validation will check BACB credential status during processing
Licensed Mental Health Counselors (LMHCs)
- Taxonomy code 101YM0800X (Mental Health Counselor) is recognized
- Enrollment via CMS-855I in PECOS; some MACs may require supplemental documentation of state licensure
- Expect 45–90 day processing given the volume of new LMHC applications filed since January 2026
Marriage and Family Therapists (MFTs)
- Taxonomy code 106H00000X (Marriage and Family Therapist) is now live
- Same CMS-855I pathway as LMHCs
Processing time benchmarks (CY2026)
Based on MAC contractor data published through early 2026:
| Provider type | PECOS (online) | Paper (CMS-855) |
|---|---|---|
| Individual provider (CMS-855I) | 30–60 days | 60–90 days |
| Group/organizational (CMS-855B) | 45–75 days | 75–120 days |
| DMEPOS supplier (CMS-855S) | 60–90 days | 90–120 days |
| New provider types (BCBA, LMHC) | 60–90 days (elevated volume) | 90–150 days |
⚠️ Risk flag: Paper applications for new provider types are running significantly longer than PECOS online submissions. If you’re a BCBA or LMHC enrolling for the first time, use PECOS — do not file on paper unless your MAC specifically instructs you to.
Revalidation workflow improvements
PECOS updated the revalidation workflow to send earlier notifications and provide a clearer status dashboard for providers tracking their revalidation status. Key changes:
- Earlier notification window: CMS now sends revalidation due notices 12 months before the due date (previously 6 months), giving providers more lead time
- Status dashboard: The PECOS “My Enrollments” dashboard now shows a clear revalidation countdown for each active enrollment record
- Automatic 180-day extension: If a revalidation application is submitted prior to the due date, CMS automatically extends the provider’s billing privileges for 180 days while the application is processed
Common PECOS errors to avoid in 2026
Based on MAC education bulletins, the most frequent 2026 PECOS submission errors are:
- Wrong taxonomy code — particularly for BCBA and LMHC applicants using legacy codes
- Missing reassignment documentation — BCBAs in group practices must complete both the 855I (individual enrollment) and 855R (reassignment) before the group can bill
- Address mismatch — PECOS address must match the address on file with NPPES; discrepancies cause processing delays
- Missing state license upload — several MACs now require a copy of the state license as part of the PECOS online submission for behavioral health providers
What to do
- If you’re enrolling for the first time: use PECOS, not paper
- Check your PECOS “My Enrollments” to verify revalidation due dates
- Ensure your NPPES address and PECOS address match
- For BCBA and LMHC applicants: double-check taxonomy code before submitting
- Ask Mae to walk you through the PECOS enrollment steps for your specific provider type