Phil Pavarini is a licensed insurance producer and is compensated when a bond is placed through this site. This page is general information, not legal, tax or fiduciary advice, and it is not a substitute for reading your plan document or contract or for advice from your own counsel. Figures shown are current as of the date on this page.
Most DMEPOS suppliers need exactly $50,000 of bond. The ones who need more usually find out late, from the enrollment contractor, after the bond has already been bought. This page is about getting the total right the first time.
Step one: count the NPIs#
The base requirement is $50,000 for each NPI for which the supplier seeks billing privileges. One NPI, $50,000. Three NPIs, $150,000 of base coverage. Make the count against the NPIs actually being enrolled or revalidated, not against the number of locations or the number of companies in a group.
Step two: check the last 10 years#
The elevated amount is $50,000 for each occurrence of an adverse legal action within the 10 years before enrollment, revalidation or reenrollment. It is in addition to the base bond, and the CMS contractor prescribes the required amount.
Look back the full 10 years before you apply. The regulation defines what counts as an adverse legal action for this purpose, and it is worth reading that definition rather than guessing.
Ready to bond your NPI for enrollment? Apply for this bond, or read the full bond details.
A worked example#
A supplier enrolling two NPIs, with one adverse legal action in the past 10 years, would be looking at $100,000 of base coverage for the two NPIs plus an elevated amount as prescribed by the CMS contractor, which the regulation sets at $50,000 per occurrence. Confirm with the contractor how the elevated amount applies across NPIs before you buy.
Keeping the total right#
Adding an NPI, a change of ownership and each revalidation are the moments the required amount can change. Treat each one as a prompt to recount, and keep the bond continuous through the changeover.
Common questions
I have two NPIs. Do I need $100,000 of bond?
For the base requirement, yes: $50,000 for each NPI for which you seek billing privileges. An elevated amount can be added on top if CMS requires it because of adverse legal actions in the past 10 years.
What triggers the elevated bond?
An adverse legal action within the 10 years before enrollment, revalidation or reenrollment. The elevated amount is $50,000 per occurrence, in addition to the base bond, as prescribed by the CMS contractor.
Who decides the elevated amount?
The CMS contractor prescribes it, based on the rule of $50,000 per occurrence of an adverse legal action in the preceding 10 years. Get the figure from the contractor before you buy the bond.
Enrolling or revalidating with Medicare?
The application covers the $50,000 DMEPOS surety bond for each NPI you bill under. The surety underwrites the supplier, and the bond must stay in force continuously.
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