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Key takeaways
- Identify which provider number is being discussed and the entity it identifies.
- Separate collecting earlier receivables from billing for care delivered after the handoff.
- A billing agent, application receipt or private agreement does not establish the buyer’s operating authority.
Short answer
Start by asking what the seller means by “the number.” The CMS-855A instructions distinguish the National Provider Identifier, or NPI, from the Medicare Identification Number, also called the PTAN. An identifier helps match a record to a provider. It does not explain which ownership action is taking place or what the buyer may do. (Source: CMS-855A, printed pages 3–4)
The general rule prohibits selling a Medicare billing number or allowing another person or entity to use it. The same regulation separately addresses ownership changes. The Medicare CHOW guide explains the wider process; this answer focuses on the difference between a transferred provider relationship and borrowed billing identity. (Source: 42 CFR 424.550)
Longer answer
For a covered CHOW, section 489.18 provides for assignment of the existing provider agreement, with continuing conditions. CMS-855A describes a CHOW in which the existing Medicare number typically transfers with that agreement. It also describes other transaction categories with different identifier outcomes. The parties must establish which actual path applies. (Sources: 42 CFR 489.18; CMS-855A, printed page 2)
That distinction prevents two opposite errors. A buyer should not assume the seller can lend out the number by contract. Nor should the parties assume that an unchanged number proves no ownership work was required. Read the provider agreement alongside the enrollment action, entity records and relevant dates.
A public NPI record is not enough. CMS says issuing an NPI does not prove the provider is licensed or holds the required credentials. A familiar trade name in a lookup result cannot replace the actual licensing and enrollment records. The Medicare certification definition separates related survey and enrollment questions. (Source: CMS NPPES notice)
What it depends on
Identify who furnished the care, when it occurred, which provider is represented on the claim and who expects the payment. Use secure records to answer those questions. The date cash arrives after a sale does not, by itself, tell you who provided the underlying service or whose billing authority applies.
Billing work needs the same clarity. CMS-855A describes a billing agency as a party contracted to prepare or submit the provider's claims. The provider remains responsible for their accuracy. That role does not turn the billing company into the care provider or decide the buyer's enrollment status. (Source: CMS-855A, printed page 39)
Home health and hospice need an additional check of the 36-month rule. Some majority-ownership changes require initial enrollment unless an exception applies. As reviewed September 8, 2026, CMS's May 13 nationwide moratorium covers initial applications, including non-exempt CIMOs. Check the moratorium guide before building the handoff around that path. (Source: CMS active moratoria)
Example
Assume a fictional buyer says it needs the seller's Medicare number for three tasks. The team has not yet completed the enrollment and contract review. No actual patient, claim or identifier is represented below, and none of these tasks is approved by the example.
| Proposed fictional task | What must be distinguished | Question to resolve |
|---|---|---|
| Receive money for care furnished before the sale | Collection rights versus the provider that furnished the care | Whose receivable is it, and what lawful collection arrangement applies? |
| Submit claims for care after the planned handoff | New service dates and the responsible provider | What enrollment and operating authority applies to that entity and period? |
| Use an outside company to prepare claims | Billing agent versus care provider | Whose claims will it prepare, under what contract and controls? |
One answer about the number cannot resolve all three tasks. A receivables clause does not establish authority for new services. A billing-service contract does not determine who may operate. The team needs to connect each task with the correct provider, records and governing requirements.
What to do next
Prepare an entity and service-date map for the Medicare Administrative Contractor and healthcare counsel. Include the proposed transaction, current agreement, relevant CMS-855A records and outstanding questions. Ask for an assessment that names the facts and dates it addresses rather than relying on a verbal assurance about keeping the number.
Review any interim management agreement separately and keep the cash forecast tied to the supported plan. The working-capital guide helps distinguish delayed receipts from new revenue. Revisit the review if the buyer, services, locations or planned effective date changes.
Frequently asked questions
Is an NPI proof that the buyer can bill Medicare?
No. An NPI identifies a provider; it does not by itself establish the required enrollment or operating authority. CMS also states that issuing an NPI does not validate licensure or credentials. Confirm the entity, enrollment decision and applicable service requirements separately.
Does submitting CMS-855A authorize the planned handoff?
Submitting the application and establishing the applicable authority are different steps. Check which entity, action and effective date the filing concerns, and what remains unresolved. A receipt or a copy of the seller’s earlier form does not establish the outcome of the buyer’s transaction.
Can an interim management agreement supply the missing permission?
The contract’s title does not grant billing privileges. Review the actual control, services, enrollment and licensing path. An outside manager’s duties also need their own authority. Do not treat a private agreement as approval to operate or bill under another provider’s identity.
Does the 36-month rule affect every type of care business?
The cited majority-ownership provision applies to home health agencies and hospices. It has a defined ownership test, period and exceptions. Other provider types and state licenses have different requirements. Identify the actual business before applying a rule or assuming it is irrelevant.
Sources
Sources are dated to distinguish current guidance from earlier publications. They support the identified facts; the transaction questions and examples are educational analysis.
- eCFR: 42 CFR 424.550 (2026). Retrieved September 5, 2026.
- eCFR: 42 CFR 489.18 (2026). Retrieved September 5, 2026.
- CMS: institutional-provider enrollment application CMS-855A (2024). Retrieved September 6, 2026.
- CMS NPPES: NPI issuance and licensure notice (2026). Retrieved September 8, 2026.
- CMS: provider enrollment moratoria (2026). Retrieved September 5, 2026.