CMS rules do not allow you to use your provider’s login credentials to manage their Medicare enrollment and ongoing revalidations in PECOS (Provider Enrollment, Chain, and Ownership System). There is a more efficient, compliant process you should be using to manage this. PECOS login.
To be compliant, you must set up a PECOS login surrogacy designation. Basically, your surrogacy designation describes your relationship with Medicare enrolled providers. The program offers you a variety of options to manage this process. Utilizing a PECOS login surrogacy designation allows you to keep track of who is making changes to the account, manage multiple providers from one login, and most importantly, is what Medicare requires if your provider is not managing his own account.
Types of Surrogacy Designations PECOS login.
Choosing and establishing the proper PECOS login surrogacy designation can be a challenge. This is done through the Identity and Access Management (I&A) System which was created to electronically streamline the management of several related CMS systems including PECOS. There are several types of accounts to choose from depending on your circumstances:
- Authorized Official
- Access Manager (formerly known as a Delegated Official)
- Staff End User
- Surrogate
NOTE: There is one more type of designation, an Individual Provider. As the name indicates, this is only for your provider. These accounts are the ones you should NOT use when managing your provider’s account.
The bottom line is, if you are managing your provider’s Medicare enrollment and revalidation through PECOS, you are required to choose and set up a surrogacy access account with your own login. Here is a breakdown of each type of surrogacy account to help to help you choose which is right for you.
Authorized Official (AO)
You must have the authority to legally conduct business on behalf of your practice to be designated an Authorized Official (AO). Typically, the AO registers the provider organization to start the process.
The CMS website defines an AO as follows:
“An appointed official (e.g., chief executive officer, chief financial officer, general partner, chairman of the board, or direct owner) to whom the organization has granted the legal authority to enroll it in the Medicare program, to make changes or updates to the organization’s status in the Medicare program, and to commit the organization to fully abide by the statutes, regulations, and program instructions of the Medicare program. See 42 CFR 424.502 for additional information.”
Within PECOS, AOs can:
- Add their organization as an employer
- Add and remove staff from their organization and control the functions that are accessible to those staff members
- Initiate or accept connection requests
- Manage staff on behalf of their organization
Access Manager (AM)
Formerly known as a Delegated Official, an Access Manager (AM) is delegated by your AO. They have the same authority as an AO—the difference is in the way they are delegated.
The CMS website defines an AM as follows:
“An individual who is delegated by the authorized official of the organization provider/supplier to report changes and updates to the enrollment record. The delegated official must be an individual with an ownership or control interest in, or be a W-2 managing employee of the provider or supplier. See 42 CFR 424.502 for additional information.”
Within your PECOS login account, AMs can:
- Add their organization as an employer
- Add and remove staff from their organization and control the functions that are accessible to those staff members
- Initiate or accept connection requests
- Manage staff on behalf of their organization
Staff End User (SEU)
If you work as an employee of the practice (i.e. Office Manager, Credentialling Specialist, etc.), you should probably be set up as an Staff End User (SEU). A provider, AO or AM would approve this designation.
The CMS website defines an SEU as follows:
“A Staff End User (SEU) is a role of the I&A system who is sent an invitation to work as staff for the organization by its Authorized (AO) or Access Manager (AM). The user’s access is managed by the AO or AM for the organization to give permissions to work on behalf of providers with approved surrogate connections. SEUs do not automatically have access to all business functions; they must be provided access by their AO or AM.”
As an SEU, you can access, view, and modify information on behalf of your practice and provider within PECOS. However, being designated an SEU does NOT allow you to:
- Approve or initiate a connection request
- Legally bind the organization
- Manage other staff
Surrogate
The final I&A designation, a Surrogate, is reserved for organizations that have business relationship with the provider or their practice. So, if your practice is owned by a hospital, their credentialing team could be designated a Surrogate in your PECOS login account. Another example would be an outside credentialing company.
The CMS website defines a Surrogate as follows:
“An Organizational Provider that has a business relationship with an Individual Provider to access, view, and modify information within CMS computer systems on their behalf; OR A Third-Party Organization that has a business relationship with an Individual Provider or Organizational Provider to access, view, and modify information within CMS computer systems on their behalf.”
A Surrogate is allowed to access, view, and modify information within PECOS on behalf of your provider. However, there are several things that a Surrogate is NOT allowed to do:
- Represent that individual practitioner or that organization
- Legally bind the individual practitioner or organization, they’re just working on their behalf
- Manage staff
- Approve or initiate a connection request
Use the below functionality chart to help you choose the best PECOS login surrogacy designation for your practice:
| Functionality | Authorized Official | Access Manager | Staff End User | Surrogate |
| Represent an Organization | YES | YES | NO | NO |
| Manage Staff | YES | YES | NO | NO |
| Approve/Manage Connections | YES | YES | NO | NO |
| Act on Behalf of Provider | YES | YES | YES | YES |
Choosing the Right Surrogacy Designation for You
The process of selecting and setting up your PECOS login surrogacy designation is complicated. Getting it right out of the gate will save you a ton of time and headaches later – not to mention ensure your compliance. The good news is, you can receive the help you need from enrollment expert, Gretchin S. Heckenlively, CPA, FHFMA. Her 90-minute online training session, PECOS: Master CMS Surrogacy Enrollment Requirements, will help you confidently and compliantly select, set up and manage your PECOS surrogacy designation. Click here to register for this useful online training session.
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