DowncodedHow Long Has Medicare Had That Enrollment Application?
CMS publishes the list of initial enrollment applications its contractors have not processed, twice a week, by name. We pulled all 336 archived builds back to June 2023. The July wave drains every autumn like it should, and 1,116 physicians have been on every single build for 1,180 days.
If you onboarded a physician who started July 1, their enrollment application landed in a pile that had 8,421 names in it.
That is the July 6 reading on Medicare's pending initial enrollment list, the second-highest in the four years CMS has archived the file.
Twice a week, on an R/P3.5D clock, CMS drops a list of every initial enrollment application its contractors have not processed. Physicians in one file, everyone else in the other.
Three columns: NPI, last name, first name. No contractor, no receipt date, no specialty, no state.
The current build is dated August 24 and went up the next afternoon. 6,087 physicians. 7,224 non-physicians.
The count is the boring part. Keeping the file is where it gets interesting.
The Wave And The Floor
We pulled all 336 archived builds, June 1, 2023 through August 24, 2026, and matched them on NPI (chart below).
The blue line does what you would guess. A hard ramp into the first week of July, then a seven-month drain. Peaks of 7,717, 8,446, 8,035 and 8,421, all four inside a three-day window on the calendar. Troughs of 3,375, 3,386, 3,279 and 3,215 in the dead of winter. Our read is the obvious one: the ACGME program year turns over on July 1, and the MACs eat a year of first-time physician enrollments in six weeks. This July's peak was 2.62x the January floor, and it has already shed 2,334 names, down 27.7% in 49 days.
That part works. The median physician row in today's file has been continuously pending 21 days, and 57.0% of the file is under thirty.
The orange band is the other thing.
1,116 physician NPIs appear in every one of the 336 builds. Unbroken, for 1,180 days. Another 448 non-physicians do the same, so 1,564 names have sat on Medicare's unprocessed pile for three years and three months without a single build dropping them.
Widen the window slightly and 1,632 physician rows, 26.8% of the file, carry a continuous spell past a year. Across both files it is 2,555 of 13,311, or 19.2%.
Fifty Days Is The Published Standard
First Coast, the Jurisdiction N MAC, posts its own processing timeframes. An initial CMS-855I filed through PECOS with no site visit, development or fingerprinting: "100% completed within 50 calendar days of receipt." With a site visit and fingerprints: "100% completed within 85 calendar days of receipt."
Fifty days.
And the floor is not draining. It stood at 1,222 last August and 1,116 this August: 106 cleared in a year, about nine a month. Hold that rate and the last of them clears in 319 years.
A Pending Row Is Not Free
Under 42 CFR 424.520(d)(1) the effective date of billing privileges is the later of the filing date of an application "that was subsequently approved by a Medicare contractor" and the date the practitioner first furnished services at the location. Approval backdates. So the waiting period is billable once the approval lands, and 424.521(a)(1) hands you thirty days in front of it.
Here's the catch. 424.44(a)(1) gives you one calendar year from the date of service to file the claim, and that clock does not pause for the contractor.
A spell longer than twelve months eats its own earliest dates of service, approval or no approval. Every row in that 1,632 is past the line.
There is a door at 424.44(b)(1). The filing limit extends where CMS or one of its contractors determines the miss "was caused by error or misrepresentation of an employee, Medicare contractor (including Medicare Administrative Contractor, intermediary, or carrier), or agent of HHS." An application logged as unprocessed across 336 consecutive public builds is about as clean a record of contractor delay as anyone is going to assemble, and it is sitting on data.cms.gov.
One caution before you use the list against anybody. 882 of the 6,087 physicians on it, 14.5%, also appear in the Order and Referring file from the same August 24 build, which CMS describes as practitioners who "have current enrollment records in Medicare." An already-enrolled physician filing an initial application with a second contractor or for a new practice location produces that overlap legitimately. A name on the pending list is not proof the practitioner cannot bill anything.
Final Thoughts
The file is a snapshot of who is waiting. It will never tell you which contractor is holding your application or what that contractor is waiting on.
What it will tell you, twice a week, for free, by name, is whether the application you filed in March is still sitting there. Nineteen percent of the rows suggest that nobody at all is checking.
Thanks for reading.