US · guidance

CMS Pub. 100-08, ch. 10, § 10.6.14

Application Fees

activein force · 2026-08-25 – presentas-observed

(The contractor shall review section 10.3 of this chapter for special instructions regarding

application fee and waiver submissions with PECOS applications.)

A. Background

Pursuant to 42 CFR § 424.514 - and with the exception of physicians, non-physician

practitioners, physician group practices, non-physician group practices, and Medicare Diabetes

Prevention Program (MDPP) suppliers – institutional providers that are (1) initially enrolling in

Medicare, (2) adding a practice location, or (3) revalidating their enrollment information per 42

CFR § 424.515 (regardless of whether the revalidation application was requested by CMS or

voluntarily submitted by the provider or supplier), must submit with their application:

• An application fee in an amount prescribed by CMS, and/or

• A request for a hardship exception to the application fee.

For purposes of this requirement, the term “institutional provider,” as defined in 42 CFR §

424.502, means any provider or supplier that submits a paper Medicare enrollment application

using the Form CMS-855A, Form CMS-855B (not including physician and non-physician

practitioner organizations), Form CMS-855S, or associated Internet-based Provider Enrollment,

Chain and Ownership System (PECOS) enrollment application. A physician, non-physician

practitioner, physician group, or non-physician practitioner group that is enrolling as a supplier

of durable medical equipment, prosthetics, orthotics and supplies (DMEPOS) via the Form

CMS-855S application must submit the required application fee with its Form CMS-855S form.

For a list of fee requirements broken out by provider/supplier and application type, refer to the

Application Fee Matrix.

Except as otherwise noted, nothing in this section 10.6.14 supersedes any other CMS directive to

the contractor pertaining to application fees.

(For purposes of this section 10.6.14, the term “provider” will be used in lieu of “institutional

provider.”)

B. Contractor Activities Upon Receipt

Upon receipt of a paper or PECOS application from a provider that is otherwise required to

submit an application fee, the contractor shall first determine whether the application is an initial

enrollment, a revalidation, or involves the addition of a practice location. If the application does

not fall within any of these categories, the contractor shall process the application as normal. If

it does fall within one of these categories, the contractor shall undertake the following:

1. Determine whether the provider has: (1) paid the application fee via Pay.gov (all payments

must be made via Pay.gov); and/or (2) included a hardship exception request with the application

or certification statement.

2. Outcomes

i. The provider has neither paid the fee nor submitted the hardship exception request-- The

contractor shall send a development letter to the provider notifying it that: (A) it has 30 days

from the date of the letter to pay the application fee via Pay.gov and any other items that may be

missing or needed; and (B) failure to do so will result in the rejection of the provider’s

application (for initial enrollments and new practice locations) or revocation of the provider’s

Medicare billing privileges (for revalidations).

ii. The provider has submitted a hardship exception request but has not paid a fee - The

contractor shall send the request and all documentation accompanying the request via e-mail to

its PEOG BFL. If CMS:

• Denies the hardship exception request – CMS will notify the provider in the decision

letter (on which the contractor will be copied) that the application fee must be paid within

30 calendar days from the date of the letter. During this 30-day period, the contractor

shall determine whether the fee has been submitted via Pay.gov. If the fee is not paid

within 30 calendar days, the contractor shall deny the application (initial enrollments and

new locations) pursuant to 42 CFR § 424.530(a)(9) or revoke the provider’s Medicare

billing privileges under 42 CFR § 424.535(a)(6) (revalidations).

(The contractor shall begin processing the application as normal if, at any time during

this 30-day period: (1) for paper applications, the provider submits a Pay.gov receipt as

proof of payment; or (2) for PECOS applications, the provider pays the fee via PECOS.)

• Approves the hardship exception request - CMS will notify the provider of such in the

decision letter (on which the contractor will be copied). The contractor shall continue

processing the application as normal.

iii. Has submitted a hardship exception request and has paid a fee - The contractor shall send the

request and all documentation accompanying the request via regular mail, fax, or e-mail to its

PEOG BFL. As the fee has been paid, the contractor shall begin processing the application

as normal.

3. PECOS Applications

(For PECOS applications, the provider must submit any required application fee (i.e., initials,

revalidations, new practice locations) or hardship waiver via PECOS at the time it submits its

application; otherwise, PECOS will not accept the application. Some of the instructions in

subsection (B)(2) may therefore be inapplicable to PECOS applications.)

As stated in section 10.3 of this chapter, application fees can be combined if multiple enrollment

records are implicated by the submission (e.g., consolidated application), but each application

still requires a separate fee. To illustrate, suppose an entity is enrolling 5 different IDTFs, and

the fee amount is $631 per IDTF. The provider can submit separate $631 fees or can combine

them into a $3,155 payment. In the case of hardship waivers, however, 5 separate hardship

waivers – one for each enrollment – must be submitted; they cannot be combined into one waiver

request.

C. Fee Amount

1. General Background

Except as stated in subsection (C)(2), the application fee must be in the amount prescribed by

CMS for the calendar year (1) in which the application is submitted (for PECOS applications) or

(2) of the postmark date (for paper applications). The current fee amount can be found via

PECOS at the following link: https://pecos.cms.hhs.gov/pecos/feePaymentWelcome.do

Fee amounts for future years will be adjusted by the percentage change in the consumer price

index (for all urban consumers) for the 12-month period ending on June 30 of the prior year.

CMS will give the contractor and the public advance notice of any change in the fee amount for

the coming calendar year.

2. Transition to Subsequent Year

There can be situations where the provider submits an application in the previous calendar year

without a required fee, the contractor develops for the fee, and the provider submits the fee in the

subsequent year. The submitted fee must be that for the subsequent year and not the preceding

year.

D. Non-Refundable

Per 42 CFR § 424.514(d)(2)(v), the application fee is non-refundable unless it was submitted

with one of the following:

1. A hardship exception request that is subsequently approved;

2. An application that was rejected prior to the contractor’s initiation of the screening process;

3. An application that is subsequently denied as a result of the imposition of a temporary

moratorium under 42 CFR § 424.570.

(For purposes of section 10.6.14(D) only, the term “rejected” includes applications that are

returned.)

In addition, the fee should be refunded if: (i) it was not required for the transaction in question

(e.g., the provider submitted a fee with its application to report a change in phone number); or

(ii) it was not part of an application submission.

E. Format

The provider must submit the application fee electronically through

https://pecos.cms.hhs.gov/pecos/feePaymentWelcome.do, either via credit card, debit card, or

electronic check.

Should the provider submit an application with a paper check or any other hard copy form of

payment (e.g., money order), the contractor shall not deposit the instrument. It shall

instead treat the situation as a non -submission of the fee and follow the instructions in

section 10.4( C) of this chapter (depending on whether a hardship exception request was

submitted). When sending the applicable letter requesting payment within 30 days, the

contractor shall explain that all payments must be made via.Pay.gov , stamp the submitted

paper check "VOID," and include the voided paper check with the letter.

F. Practice Locations

DMEPOS suppliers, federally qualified health centers (FQHCs), independent diagnostic testing

facilities (IDTFs), and certain other provider and supplier types described in this chapter must

individually enroll each site. The enrollment of each site thus requires a separate fee. For all

other providers (except physicians, non-physician practitioners, and physician and non-physician practitioner groups, none of which are required to submit the fee), a fee must

accompany any application that adds a practice location. (This includes the addition of a hospital

unit – such as a psychiatric unit – in the Practice Location section of the Form CMS-855A.) If

multiple locations are being added on a single application, however, only one fee is required;

indeed, the fee for providers that are not required to separately enroll each location is based on

the application submission, not the number of locations listed on a single application.

G. Other Application Fee Policies

1. PECOS Enrollment Records

a. Paper Applications - The fee is based on the Form CMS-855 application submission, not on

how enrollment records are created in PECOS. For instance, suppose a hospital submits an

initial Form CMS-855A. In the Identifying Information/hospital type section of the application,

the hospital indicates that it has a psychiatric unit and a rehabilitation unit. Separate PECOS

enrollment records must be created for each unit. However, only one application fee is required

because only one Form CMS-855A application was submitted.

b. PECOS Applications – In a similar vein, the fee is based on the number of applications

involved. Even if the provider submits one set of data into PECOS, it may involve several

different applications, thus requiring separate fees. To illustrate, assume a provider exists in

Tennessee, Arkansas, and Missouri, each of which is in a separate contractor jurisdiction. As

discussed in section 10.3 of this chapter, the group may submit a consolidated application (e.g.,

one set of data encompassing all three enrollments), which PECOS would then split into three

separate applications. Three fees must be paid, however, because three separate enrollment

applications are involved.

2. Group Practices/Clinics

A physician/non-physician practitioner clinic or group practice enrolling via the Form CMS-

855B is exempt from the fee even if it is tribally-owned/operated or hospital-owned. Yet if a

hospital is adding a physician/non-physician practitioner clinic or group practice to its Form

CMS-855A enrollment, a fee is required because the hospital is adding a practice location.

3. Change of Ownership via Form CMS-855B or Form CMS-855S

A provider or supplier need not pay an application fee if the application is reporting a change of

ownership via the Form CMS-855B or Form CMS-855S. (For providers and suppliers reporting

a change of ownership via the Form CMS-855A, the ownership change does not necessitate an

application fee if the change does not require the provider or supplier to enroll as a new provider

or supplier.)

4. Reporting a Change in Tax Identification Number

A provider need not pay an application fee if the application is reporting a change in TIN for a

Part A, Part B, or DMEPOS provider or supplier.

5. Requesting a Reactivation

A provider need not pay an application fee to reactivate Medicare billing privileges unless the

provider/supplier was deactivated for failing to respond to a revalidation request, in which case

the resubmitted application constitutes a revalidation (not a reactivation) application, hence

requiring a fee.

6. Changing the Physical Location of an Existing Practice Location

A provider need not pay an application fee when changing the physical location of an existing

practice location (as opposed to reporting an additional/new practice location).

The application fee requirement is separate and distinct from the site visit requirement and risk

categories discussed in this chapter. Physicians, non-physician practitioners, physician groups,

and non-physician practitioner groups are exempt from the application fee even if they fall

within the “high” level of categorical screening per 42 CFR § 424.518. Likewise, physical

therapists enrolling as individuals or group practices need not pay an application fee even though

they fall within the “moderate” level of categorical screening and are subject to a site visit.

H. Refund Requests

Unless otherwise approved by CMS, the provider must request a refund no later than 150 days from

the date it submitted its application. In its request, the provider shall include documentation

acceptable to process the refund request. For credit card refunds, the provider shall include its

Pay.gov receipt or the Pay.gov tracking ID number.

If a refund is requested and the fee was paid via ACH Debit, the contractor shall collect from the

provider a completed “Authorization and Payment Information Form for Electronic Funds

Transfer” form (previously furnished to contractors) and submit it to the

PEMACReports@cms.hhs.gov mailbox. In the subject line of this e-mail, the contractor shall:

(1) identify the provider’s legal business name, National Provider Identifier (NPI), and the

Pay.gov Tracking ID; and (2) include the completed, previously-mentioned form.

I. Institutional Provider and Fee: Year-to-Year Transition

There may be isolated instances where, at the end of a calendar year, a provider pays the fee

amount for that year (Year 1) but the submission date (for Internet-based PECOS applications) or

the application postmark date (for paper applications) falls in the beginning of the following year

(Year 2). Assuming that Year 2’s fee is higher than Year 1’s, the provider must pay the Year 2

fee. The contractor shall thus: (1) send an e-mail to its PEOG BFL requesting a full refund of the

fee and including any pertinent documentation in support of the request; and (2) send a letter to

the provider notifying it that (i) it has 30 days from the date of the letter to pay the correct fee

amount (i.e., the Year 2 amount) via Pay.gov and (ii) failure to do so will result in the rejection

of the provider’s application (for initial enrollments and new practice locations) or revocation of

the provider’s Medicare billing privileges (for revalidations). The letter shall also state that

because a hardship exception request was not submitted with the original application, CMS will

not consider granting a hardship exception in lieu of the fee.

J. Hardship Exception

1. Background

A provider requesting a hardship exception from the application fee must include with its

enrollment application a letter (and any supporting documentation) that describes the hardship

and why the hardship justifies an exception. If a paper Form CMS-855 application is submitted,

the hardship exception letter must accompany the application; if the application is submitted via

PECOS, the hardship exception letter must accompany the application (i.e., the provider must

upload the letter and supporting documentation into PECOS). Hardship exception letters shall

not be considered if they were submitted separately from the application. If the contractor

receives a hardship exception request separately from the application or certification statement, it

shall: (1) return it to the provider; and (2) notify the provider via letter, e-mail or telephone that it

will not be considered.

2. Criteria for Determination

The application fee generally should not represent a significant burden for an adequately

capitalized provider. Hardship exceptions should not be granted when the provider simply

asserts that the imposition of the application fee represents a financial hardship. The provider

must instead make a strong argument to support its request, including furnishing comprehensive

documentation (which may include, without limitation, historical cost reports, recent financial

reports such as balance sheets and income statements, cash flow statements, tax returns, etc.).

Other factors that may suggest that a hardship exception is appropriate include the following:

a. Considerable bad debt expenses,

b. Significant amount of charity care/financial assistance furnished to patients,

c. Presence of substantive partnerships (whereby clinical and/or financial integration are

present) with those who furnish medical care to a disproportionately low-income population,

d. Whether an institutional provider receives considerable amounts of funding through

disproportionate share hospital payments, or

e. Whether the provider is enrolling in a geographic area that is a Presidentially-declared disaster

under the Robert T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. 5121-

5206 (Stafford Act).

Upon receipt of a hardship exception request with the application, the contractor shall send the

request and all documentation accompanying the request via regular mail, fax, or e-mail to its

PEOG BFL. CMS has 60 calendar days from the date of the contractor’s receipt of the hardship

exception request to determine whether it should be approved; during this period, the contractor

shall not commence processing the provider’s application. CMS will communicate its decision

to the provider and the contractor via letter, after which the contractor shall carry out the

applicable instructions in section 10.6.14(K) below.

If the provider fails to submit appropriate documentation to support its request, the contractor

need not contact the provider to request it. The contractor can simply forward the request “as is”

to its PEOG BFL. It is ultimately the provider’s responsibility to furnish the necessary

supporting evidence at the time it submits its hardship exception request.

K. Appeals of Hardship Determinations

A provider may appeal CMS’ denial of its hardship exception request via the procedures outlined

below:

1. If the provider is dissatisfied with CMS’ decision to deny a hardship exception request, it may

file a written reconsideration request with CMS within 60 calendar days from receipt of the

notice of initial determination (e.g., CMS’ denial letter). The request must be signed by the

individual provider or supplier, a legal representative, or any authorized official within the entity.

Failure to file a reconsideration request within this timeframe is deemed a waiver of all rights to

further administrative review.

The reconsideration request should be mailed to:

Centers for Medicare & Medicaid Services

Center for Program Integrity

Provider Enrollment & Oversight Group

Attn: Division of Provider Enrollment Appeals

7500 Security Boulevard

Mailstop: AR-19-51

Baltimore, MD 21244-1850

Notwithstanding the filing of a reconsideration request, the contractor shall still implement the

post-hardship exception request instructions in this section 10.6.14(K). A reconsideration

request, in other words, does not stay the implementation of section 10.6.14(K)’s instructions.

The CMS has 60 calendar days from the date of the reconsideration request to render a decision.

The reconsideration shall be: (a) conducted by a CMS staff person who was independent from

the initial decision to deny the hardship exception request; and (b) based on CMS’ review of the

original letter and documentation submitted by the provider.

Upon receipt of the reconsideration, CMS will send a letter to the provider to acknowledge

receipt of its request. In its acknowledgment letter, CMS will advise the requesting party that the

reconsideration will be conducted and a determination issued within 60 days from the date of the

request.

If CMS denies the reconsideration, it will notify the provider of this via letter, with a copy to the

contractor. If CMS approves the reconsideration request, it will notify the provider of this via

letter, with a copy to the contractor, after which the contractor shall process the application as

normal, or, to the extent applicable:

i. If the application has already been rejected, request that the provider resubmit the application

without the fee, or

ii. If Medicare billing privileges have already been revoked, reinstate said billing privileges in

accordance with existing instructions and request that the provider resubmit the application

without the fee.

Corrective Action Plans (CAPs) may not be submitted in lieu of or in addition to a request for

reconsideration of a hardship exception request denial.

2. If the provider is dissatisfied with the reconsideration determination regarding the application

fee, it may request a hearing before an Administrative Law Judge (ALJ). Such an appeal must

be filed, in writing, within 60 days from receipt of the reconsideration decision. ALJ requests

should be sent to:

Department of Health and Human Services

Departmental Appeals Board (DAB)

Civil Remedies Division, Mail Stop 6132

330 Independence Avenue, S.W.

Cohen Bldg, Room G-644

Washington, D.C. 20201

ATTN: CMS Enrollment Appeal

Failure to timely request an ALJ hearing is deemed a waiver of all rights to further administrative

review.

If the ALJ reverses PEOG’s reconsideration decision and approves the hardship exception

request but the application has already been rejected, the contractor – once PEOG informs it of

the ALJ’s decision - shall notify the provider via letter, e-mail, or telephone that it may resubmit

the application without the fee. If the provider’s Medicare billing privileges have already been

revoked, the contractor shall reinstate said billing privileges in accordance with existing

instructions and request that the provider resubmit the application without the fee.

3. If the provider is dissatisfied with the ALJ’s decision, it may request Board review by the

Departmental Appeals Board (DAB). Such request must be filed within 60 days after the date of

receipt of the ALJ‘s decision. Failure to timely request a review by the DAB is deemed a waiver

of all rights to further administrative review.

If the DAB reverses the ALJ’s decision and approves the hardship exception request but the

application has already been rejected, the contractor - once PEOG informs it of the DAB’s

decision - shall notify the provider via letter, e-mail, or telephone that it may resubmit the

application without the fee. If the provider’s Medicare billing privileges have already been

revoked, the contractor shall reinstate said billing privileges in accordance with existing

instructions and request that the provider resubmit the application without the fee.

To the extent permitted by law, a provider dissatisfied with a DAB decision may seek judicial

review by timely filing a civil action in a United States District Court. Such requests shall be

filed within 60 days from receipt of the notice of the DAB‘s decisi(Rev. 12209; Issued: 08-17-

23; Effective: 09-18-23; Implementation: 09-18-23)