Medicare Surrogacy

(Identity & Access Management System)

Zetter HealthCare provides expert consulting services in Medicare Surrogacy. David Zetter, our president, is one of three consultants in the U.S. who has worked directly with CMS to develop the surrogacy program. As a result of our access to CMS, Zetter HealthCare can provide you with an unparalleled experience in Medicare Surrogacy.

What is a Surrogate?

medicareA surrogate is someone who is authorized to access, view, and modify information on behalf of their employer within the NPPES, PECOS, and/or EHR websites. The employer can be a practice, provider organization, or any other type of organization that employs or works with healthcare providers. Additionally, this includes third-party vendors, such as credentialing and billing companies, practice management consulting firms, etc.

Federal Medicare regulations forbid providers from sharing their login credentials with others to access their accounts and information. For this reason, Centers for Medicare & Medicaid Services, or CMS, developed the surrogacy program. The surrogacy program audits surrogates similarly to providers so they may work in their systems.

You will notice with CMS, the term “provider” refers to hospitals, nursing homes, assisted living facilities, etc. These are organizations that would complete an 855A enrollment application. Suppliers are practitioners of any specialty, group practices, IDTFs, and other types that complete the following enrollment application types:  855B, 855I, 855O, and 855R. The healthcare industry refers to clinicians as providers. However, it’s worth noting the government does not agree with this, so they identify them differently. You will also see CMS refer to clinicians as providers as well.

Why Was The Surrogate Program Developed?

Providers must personally enter most of the data when enrolling providers under Medicare’s Provider Enrollment Chain Ownership System. This is one of the biggest frustrations practices and supplier/provider types face during enrollment.

In 2014, CMS deployed a “surrogate” program allowing providers/practices to delegate enrollment and revalidation functions to staff and third-party vendors. Moreover, surrogates may act on behalf of any provider or supplier type in Medicare. This means any licensed enrolled clinician, group practice, or facility that employs providers may utilize a surrogate within their organization. Alternatively, they may also utilize a third-party vendor to act as a surrogate on behalf of the organization or provider.

Medicare Surrogacy Enrollment

To get started, any employee can enroll in the PECOS Identity & Access Management System (I&A). This may be done by anyone prior to working for a healthcare provider or third party vendor. Your I&A account will stay with you throughout your healthcare career no matter how many employers your career may entail.

I&A enrollment requires users to have a unique email address and password. In addition, the identification of each person is validated in a manner similar to how a credit bureau might validate someone’s identity. Expect to answer a series of specific, personal questions during the process.

Medicare Surrogacy Application

The applicant needs to send a paper application for CMS to review. You should plan for this process to take 2-3 weeks in total. However, if an applicant is denied, he or she may reapply immediately.

Once approved, the surrogate applicant and the provider connect in a way similar to how friends are made on Facebook.

The surrogate sends a request for access to the provider, who then needs to log into PECOS I&A and approve the request. An email is not sent to prompt the provider, so it is important the provider knows action is needed. Once permission is granted, it is effective in real-time. The provider may choose to request a connection with a surrogate in the same fashion as the request by the surrogate.

CMS uses several provider enrollment systems. Organizational providers and suppliers must use the Identity & Access Management (I&A) System to name an Authorized Official (AO) to work in CMS systems. The I&A System allows you to:

  • Use the National Plan and Provider Enumeration System (NPPES) to apply for and manage National Provider Identifiers (NPIs)
  • Use PECOS to complete Medicare enrollment or update or revalidate your current enrollment information
  • Register to get Electronic Health Record (EHR) incentive payments for eligible professionals and hospitals who adopt, use and upgrade, or demonstrate meaningful EHR technology (Medicaid)


Surrogacy allows you to do the following:

  • Efficiently add, modify and terminate providers from your group login
  • Comply with access rules for the PECOS Identity & Access (I&A) Management System
  • Correctly choose your designation: Authorized/Delegated Official (AO/DO) or Staff End-User
  • Efficiently manage organizational and individual practitioner enrollments in PECOS
  • Successfully use your PECOS login to also manage your provider NPI records within the NPPES system
  • More easily and quickly update practitioner information to avoid Medicare deactivation
  • Easily add, terminate and authorize staff as PECOS users to streamline workflow

And so much more.

The surrogate gains access to the provider’s entire record in PECOS. The provider may also grant access to his or her record for the Electronic Health Records (EHR) Incentive Program (the Meaningful Use Program, still being used for Medicaid heavy practices) and the National Plan and Provider Enumeration System (NPPES).

Remember, the approval can be for any of the three systems, or all of them. The provider is not able to restrict subsets of information within each of those systems. It’s all or nothing.

Medicare Surrogacy Revocation

If an authorized employee surrogate leaves your organization, each provider must log into the I&A system and revoke the surrogate authorization immediately. As a result, the surrogate no longer has access to their records. The revocation is effective immediately. However, you are exposed until the revocation is done. Be sure to add this to your employee exit interview or exit process.

CMS Organizations and Users

CMS allows various types of organizations and users to work in their systems. The type of user depends on the individual’s relationship with you and the duties they perform in your practice.

You may choose other users to act for your organization to manage connections and staff, including approving other system-authorized users. Depending on your professional relationships with other providers, the CMS External User Services (EUS) Help Desk may ask you for additional information for validation.

Authorized Officials

Organizational providers or suppliers must appoint and authenticate an Authorized Official (AO) through the I&A System to work in PECOS for them. That individual must meet the AO regulatory definition. For example, an AO is a chief executive officer, chief financial officer, general partner, chair of the board, or direct owner to whom the organization gives legal authority to enroll in the Medicare Program.

You must respond to your employer’s AO invitation or initiate the request yourself. Then, use PECOS for your provider or supplier organization. As an AO, you are responsible for approving PECOS user system requests to work on behalf of the provider or supplier organization. Regularly check your email and take the requested actions.

Designated Officials

AOs may delegate their responsibilities to a Designated Official (DO), who can manage staff for their organizations.

AOs or DOs may invite a Staff End User (SEU) or Surrogate to access PECOS for their organization. Next, an SEU or surrogate may log in to access, view, and modify CMS system information. However, they may not represent the practice, manage staff, sign enrollment applications, or initiate or accept connections.

Zetter HealthCare and CMS

David Zetter is an original member of CMS’s PECOS Power User Group and assisted CMS in designing and developing the surrogacy system. In fact, at the first meeting several years ago, David advised the Provider Enrollment Operations Group that providers did not do their own enrollments or updates. Most providers have someone do it on their behalf. This was news to CMS. After that, CMS realized they needed a system that allowed others to act on behalf of providers in a legal and compliant method.

Aside from assisting in the development of the surrogacy system, David provides continual feedback and updates on the medicare surrogacy system. He also speaks every six months at national enrollment conferences and forums around the country to educate providers, staff, and organizations how the surrogacy program works, how to set it up, and how to maintain provider accounts and information.

For more information on Medicare Surrogacy, call the professionals at Zetter HealthCare at (717) 691-6768.

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