Medicare Program Integrity Manual (Pub. 100-08), Ch. 10 § 10.3.1.3.2
(Personal Identifying Information) – Form CMS-855I
10.3.1.3.2 - Section 2 (Personal Identifying Information) – Form CMS-855I
(Rev. 13355; Issued: 08-13-25; Effective: 05-05-25; Implementation: 05-05-25)
A. Licensure Information
1. General Instructions
(The extent to which the applicant must complete the licensure information depends upon the
supplier type involved. Requirements will vary by supplier type and by location; for instance,
some states may require a particular supplier type to be “certified” but not “licensed,” or vice
versa. (The license and certification “Not Applicable” checkboxes are for instances where a
state does not require licensure).)
The only licenses that must be submitted with the application are those required by Medicare or
the state to function as the supplier type in question. Licenses and permits that are not of a
medical nature are not required. In addition, and as mentioned above, instances can occur where
the supplier need not be licensed at all in a particular state; the contractor shall still ensure,
however, that the supplier meets all applicable state and Medicare requirements.
The contractor shall verify that the supplier is licensed and/or certified to furnish services in:
• The state in which the supplier is enrolling.
• Any other state within the contractor’s jurisdiction in which the supplier (per the “Practice
Location Information” section of the Form CMS-855I) will maintain a practice location.
The contractor shall also ensure that the individual answers “Yes” or “No” to the Section 2(B)(1)
question regarding compact licenses if individual indicates that the individual is licensed. (See
subsection (A)(6) below for more information on compact licenses.)
2. Notarization
If the applicant submits a license that is not notarized or "certified true," the contractor shall
verify the license with the appropriate state agency. (A notarized copy of an original document
has a stamp that states "official seal," along with the name of the notary public, the state, the
county, and the expiration date of the notary's commission. A certified "true copy" of an original
document has a raised seal that identifies the state and county in which it originated or is stored.)
3. Temporary Licenses
If the supplier submits a temporary license, the contractor shall note the expiration date in
PECOS. Should the supplier fail to submit the permanent license after the temporary license
expiration date, the contractor shall initiate revocation procedures. (A temporary permit – one in
which the applicant is not yet fully licensed and must complete a specified number of hours of
practice to obtain the license – is not acceptable.)
4. Revoked/Suspended Licenses
If the applicant had a previously revoked or suspended license reinstated, the applicant must
submit a copy of the reinstatement notice with the application.
5. License Expiration/Revocation Dates for Non-Certified Suppliers
For expired licenses, the contractor shall enter in PECOS the day after the expiration as the
expiration date. For revoked and suspended licenses, the contractor shall enter in PECOS the
revocation date (not the day after) as the expiration date. (See section 10.6.19(T) of this chapter
for special instructions related to periodic license reviews.)
6. Interstate License Compacts
A new trend in medicine has arisen involving interstate license compacts. While physician
compacts streamline the licensure process for physicians who want to practice in multiple states,
a separate license from each state in which the physician intends to practice is still issued (if all
requirements are met). CMS will continue to rely on the license issued by the state medical board
to help confirm compliance with federal requirements.
In a similar vein, certain non-physician practitioner (NPP) compacts allow the NPP to work in a
compact member state (other than the individual’s home state) without going through the normal
process for licensure in the remote state. NPPs working under the authorization of such a
compact must meet both the licensure requirements outlined in the primary state of residence and
those established by the compact laws adopted by the legislatures of the interstate compact
states.
At present, there are interstate compacts involving physicians, physical therapists, occupational
therapists, speech language pathologists, and psychologists (though none for nurse practitioners).
More are possible.
Licenses obtained through an interstate license compact for the above supplier types shall be
treated as valid, full licenses for the purposes of meeting federal requirements. The contractor
shall thus accept Form CMS-855I applications from applicants reporting a license obtained via
an interstate license compact. In addition, the contractor shall attempt to verify the interstate
license obtained through the compact using the state licensing board website(s) or compact
website (if one exists); if neither technique can confirm the interstate license, the contractor shall
request documentation from the supplier that validates said data.
B. Correspondence Address, Medical Record Correspondence Address, and Telephone
Number
1. Correspondence Address
The correspondence address must be one where the contractor can directly contact the applicant
to resolve any issues once the supplier is enrolled in Medicare. It cannot be the address of a
billing agency, management services organization, or the supplier’s representative (e.g., attorney,
financial advisor). It can, however, be a P.O. Box or, in the case of an individual practitioner,
the person’s home address.
The contractor need not verify the correspondence address.
2. Medical Records Correspondence Address
The medical records correspondence address must be one where the contractor can directly
contact the applicant regarding medical records once the supplier is enrolled in Medicare. It
cannot be the address of a billing agency, management services organization, or the supplier’s
representative (e.g., attorney, financial advisor). It can, however, be a P.O. Box or, in the case of
an individual practitioner, the person’s home address.
Note that: (1) the contractor need not verify the medical records correspondence address; and (2)
the medical records correspondence address does not apply to individuals reassigning all
benefits.
3. Telephone Number
The supplier may list any telephone number as the correspondence or medical record
correspondence phone number. The number need not link to the listed correspondence address.
If the supplier fails to list a correspondence or medical record telephone number and it is
required for the application submission, the contractor shall develop for this information –
preferably via the PCV, e-mail, or fax. The contractor shall accept a particular phone number if
it has no reason to suspect that it does not belong to or is not somehow associated with the
supplier. The contractor need not verify the telephone number.
C. E-mail Addresses
An e-mail address listed on the application can be a generic e-mail address. It need not be that of
a specific individual. The contractor may accept a particular e-mail address if it has no reason to
suspect that it does not belong to or is not somehow associated with the supplier.
D. Specialties
A physician must indicate the supplier specialty via a checkmark, an “X,” or other symbol; if the
physician has more than one specialty, these specialties must be indicated, showing "P" for
primary and "S" for secondary. (Non-physician practitioners must indicate their supplier type.)
The contractor shall verify that any supplier identifying a secondary specialty on the Form CMS-
855I application has the appropriate medical license. The contractor shall validate the license
using the state’s medical license website. If an active license is not found, the contractor shall
develop via telephone, fax, email, or mail to confirm the supplier’s intent and to obtain a copy of
the license, if applicable.
The contractor shall deny the application if the individual fails to meet the requirements of the
physician specialty (primary and/or secondary) or supplier type.
Notwithstanding the foregoing instructions in this subsection (D), if a Form CMS-855I
enrollment application is submitted to report a primary or secondary specialty change, the
contractor shall not contact the physician, practitioner, or contact person directly to confirm
either the change itself or the individual’s intent to change specialty.
E. Education
1. Non-Physician Practitioners - The contractor shall verify all required educational information
for non-physician practitioners. While the non-physician practitioner must meet all federal and
state requirements, the individual need not provide documentation of courses or degrees taken to
satisfy these requirements unless the contractor requests it. To the maximum extent possible, the
contractor shall use means other than the practitioner’s submission of documentation---such as a
state or school web site---to validate the person’s educational qualifications.
2. Physicians - A physician need not submit a copy of the degree unless the contractor requests
it. To the maximum extent possible, the contractor shall use means other than the physician’s
submission of documentation---such as a state or school web site--to validate the person’s
educational status.
F. Relocation to a New State: License Reviews
When a practitioner submits a Form CMS-855I application to either (1) add a practice location in
a new state or (2) relocate to a new state entirely, the contractor that received the application
shall review state licensing board information for the “prior” state to determine:
• Whether the practitioner had a medical license revoked, suspended, or inactive (due to
retirement, death, or voluntary surrender of license), or otherwise lost a license, and
• If the practitioner has indeed lost a medical license, whether this was reported via the Form
CMS-855I within the timeframe specified in 42 CFR § 424.520.
If the practitioner is currently enrolled and did not report the adverse action to Medicare in a
timely manner, the contractor shall---unless another directive in this chapter instructs otherwise,
such as section 10.6.6----revoke the practitioner’s Medicare enrollment and establish the
appropriate reenrollment bar length. If the practitioner is submitting an initial enrollment
application (e.g., is moving to a new state and contractor jurisdiction) and did not report the
adverse action in Section 3 of the CMS-855I, the contractor shall--- unless another directive in
this chapter instructs otherwise---- deny the enrollment application.