Date: November 25, 2025
Attention: Providers
Call to action: This communication is an update to a previously published Texas Medicaid Healthcare Partnership (TMHP) bulletin from May 2023. This alert offers clarity and more information about the Provider Enrollment and Management System (PEMS) change of ownership (CHOW) process.
How this impacts providers: CHOW with Different NPIs
If the buyer (new owner) and seller (old owner) have different National Provider Identifiers (NPIs), the following procedures apply:
- If the NPI or Atypical Provider Identifier (API) of the new owner—listed as a current owner on the PEMS Ownership/Controlling Interest page—is already enrolled in PEMS, the new owner must submit a PEMS-Existing Enrollment application using that NPI/API.
- If the new owner’s NPI or API is not yet enrolled in PEMS, the new owner must submit a PEMS-New Enrollment application under the new NPI.
CHOW with the Same NPIs
If the buyer (new owner) and seller (old owner) share the same NPI and the buyer does not have an active enrollment that is associated with that NPI or API, the buyer must submit a PEMS-New Enrollment application. Submitting a PEMS-New Enrollment application will establish a new profile for the same NPI, which will reflect the updated ownership. The previous profile, which represents the former ownership, will be disenrolled.
The following table lists the appropriate PEMS application type for each CHOW scenario:
| NPI/API Change? | PEMS Application Type |
| No | New Enrollment |
| Yes, and the new owner’s NPI/API is active in PEMS | Existing Enrollment |
| Yes, and the new owner’s NPI/API is not active in PEMS | New Enrollment |
Next step for Providers: Providers should share this communication with their staff and follow the guidance offered in this alert and if needed, seek additional information from the resources listed below.
Criteria for CHOW
Some scenarios may appear to be a CHOW but do not meet the criteria for a true CHOW. It is essential to verify whether a true CHOW has occurred by reviewing the criteria that are listed in the Code of Federal Regulations §489.18 Change of ownership or leasing: Effect on provider agreement.
The following scenarios are not CHOWs:
- Stock transfers and corporate mergers
- Changes of information such as changes of principals or controlling interest
Provider Resources:
If you have any questions, please email Provider Relations at providerrelations@texaschildrens.org.
For access to all provider alerts: www.texaschildrenshealthplan.org/provideralerts.
