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CMS-116 Form: How to Fill It Out

9 min read

Form CMS-116 is the CLIA application: the same five pages start a new lab, renew a survey, change a certificate type or report a new director. This walks through the current edition, (03/24), one section at a time, with the mistakes that send it back and the changes that mean filing it again. Read from the CMS form and 42 CFR 493 on 23 October 2026.

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Ten sections, one certificate: the name typed in Section I is the name the certificate prints.

The form at a glance

  • FormCMS-116 (03/24)
  • OMB number0938-0581, expires 03/31/2027
  • Waiver labs fillSections I–VI and IX–X
  • PPM labs fillSections I–VII and IX–X
  • Compliance, accreditationSections I–X
  • Send toyour State Agency, no payment

Before you start

Download the current edition from CMS. It is a fillable PDF: type your answers and save it. The footer of every page should read Form CMS-116 (03/24), and the paperwork notice on page 1 gives OMB No. 0938-0581, expiration 03/31/2027. (CMS's forms page shows those two dates swapped; the form itself is the one to trust.)

Have these to hand before you open it:

  • Your certificate type. If you are unsure, the CLIA certificate finder decides it in four questions.
  • Every test you run or plan to run: analyte, test name, manufacturer, and for non-waived tests whether it is moderate or high complexity (the FDA database has each categorization).
  • An estimated annual volume for each specialty.
  • The federal tax ID, and an email address the whole lab can read.
  • For any non-waived certificate, PPM included, the director's proof of qualifications: state licence where applicable, diploma or transcript, credentials and lab experience. A foreign degree needs an equivalency evaluation.

CMS estimates an hour to complete it. Check with your State Agency first: some states add their own licence and forms, and labs in Washington and New York start with the state programs CMS lists.

Sections I to V: the lab and its certificate

I. General information

Tick one reason: initial application, survey (an initial survey or a recertification), change in certificate type, change in laboratory director, or other changes such as a new location or a closure. A first application gives an anticipated start date; a change gives the date it takes effect.

  • CLIA number. Leave it blank on a first application; one is assigned. On anything else, copy it from your certificate. The instructions call it “10 digit”, but the third character is always the letter D (what the format tells you): a made-up example is 12D3456789.
  • Facility name. Be specific. What you write here is what appears on the certificate.
  • Email. Tick “receive notifications including electronic certificates via email” and the address is required. The fee notice and the certificate arrive there.
  • Addresses. The facility address is where testing happens and cannot be a P.O. box or mail stop. Mailing and corporate addresses are optional; pick which of the three receives the fee coupon and which receives the certificate.
  • Director. Name (last, first, initial), phone and credentials.

II. Type of certificate requested

Check only one, matching the highest complexity you perform. The box tells you how much of the form to fill: waiver labs complete Sections I to VI and IX to X, PPM labs I to VII and IX to X, compliance and accreditation labs all of I to X. An accreditation applicant also ticks its accreditor (The Joint Commission, AABB, A2LA, ACHC, CAP, COLA or ASHI; see the CMS-approved list) and must show accreditation, or an application for it, within 11 months of receiving its registration certificate.

III. Type of laboratory

One code from 01 to 29 for the setting where testing happens: 21 physician office, 15 independent, 14 hospital, 20 pharmacy. Dentists and chiropractors use 22 practitioner other. A mobile laboratory (19) attaches the VIN of every vehicle.

IV. Hours of laboratory testing

Only the hours when testing actually happens, in HH:MM. The instructions say not to use military time; tick 24/7 if it applies.

V. Multiple sites

One certificate can cover several sites only under three exceptions: a lab with no fixed location (mobile units, health fairs), limited public health testing by a not-for-profit or government lab (no more than 15 moderate complexity or waived tests per certificate), or hospital labs on one campus under common direction (§ 493.35(b), § 493.55(b)). Otherwise each location files its own form.

Note

Accreditation still starts here

A lab choosing accreditation files this form with the State Agency too. Its first certificate is a registration certificate, which lets it test until CMS receives verification from the accreditor.

Takeaway

Section I's name and address are printed on your certificate. Type them exactly as you want them read.
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Sections VI to VIII are where the test menu and its volume go, box by box.

Sections VI to VIII: tests and annual volume

VI. Waived testing

List each waived analyte with its test name and manufacturer (the form's example: Streptococcus group A, a rapid strep kit, its maker), then one estimated total for all waived tests. Waiver-only labs stop here and skip VII and VIII. Dipstick urinalysis belongs in this section.

VII. PPM testing

Tick each provider-performed microscopy procedure you do from the nine on the form: wet mounts, KOH preps, pinworm exams, fern tests, post-coital exams, urine sediment, nasal smears for granulocytes, fecal leukocytes and qualitative semen analysis. Give their total volume. A compliance or accreditation lab also carries this volume into Section VIII.

VIII. Non-waived testing

List each non-waived test with its manufacturer and an M (moderate) or H (high). Then tick each specialty or subspecialty, each with a three-digit code (routine chemistry 310, urinalysis 320, hematology 400, bacteriology 110), and enter its estimated annual volume and, for accreditation, the accreditor beside it. A multi-site certificate counts all sites.

The volume rules are on the form: leave out tests not subject to CLIA, waived tests, and tests run “for quality control, calculations, quality assurance or proficiency testing”. Count each analyte of a panel (§ 493.638(c)(1)); the form's lipid panel counts as 4. The instructions add rules by specialty: a culture once per request per specimen, histopathology by block, cytology by slide, a WBC differential as one.

This total is what sets a compliance or accreditation lab's fee schedule under § 493.638(c)(3). The CLIA fee calculator turns it into CMS's two-year bill.

Takeaway

Section VIII's total and its specialty count decide your fee. Count it the form's way, not the analyzer's.

Sections IX and X: ownership, other labs, signature

IX. Type of control

One box: voluntary nonprofit (religious, private or other), for profit (proprietary), or government (city, county, state, federal, other). The form also asks whether a non-U.S. government or entity has partial or full ownership or control, and if so the country.

X. Director affiliation with other laboratories

List every other separately certified lab this director runs, waiver labs included, with its CLIA number. The instructions set the ceiling: for PPM, compliance or accreditation, one person can direct no more than five certificates.

The signature

The owner or director signs “in ink or use a secure electronic signature”, with printed names for both the director and the owner. The signature agrees to run the lab to CLIA's standards and to let HHS inspect it and its records “at any reasonable time”. For the form, an owner is anyone with any interest in the lab, except through publicly traded stock.

Form and instructions: Form CMS-116 (03/24), read 23 October 2026.

Mistakes that get it returned

Each of these is covered by a line of the form or its instructions, so each is avoidable before the envelope goes out.

Common Form CMS-116 mistakes and what the form says about each
MistakeWhat the form says
A section left empty“Incomplete applications cannot be processed and will be returned to the facility.” Fill every section your Section II box names.
No proof of the director’s qualificationsRequired for every non-waived certificate, PPM included. “Failure to submit this information will delay the processing of your application.”
A foreign degree sent without an evaluationForeign credentials need an equivalency evaluation, or processing waits.
A P.O. box as the facility addressThe physical address must be where testing happens. A P.O. box can only go in the mailing or corporate address.
A check stapled to the form“Do not send any payment with your completed 116 application.” CMS bills you afterwards.
Waived tests, QC or calculations in the Section VIII totalThey are excluded, and an inflated total puts the lab in a higher fee schedule.
PPM volume left out of Section VIIICompliance and accreditation labs include their PPM tests in the non-waived total.
A certificate below your highest complexityChoose by the most complex test you run. One moderate complexity test means no Certificate of Waiver.
A director over the limitFor PPM, compliance or accreditation, one person directs no more than five certificates. Section X shows the count.
Mailed to the address on page 1That is CMS’s paperwork-burden office, which says not to send applications there. The form goes to the State Agency.
Caution

An old copy on the shared drive

Practices often refile from a saved copy. Download the form fresh from CMS each time and check that the footer reads (03/24); if CMS has posted a newer edition, ask your State Agency whether it still takes the old one.
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One empty section and the whole form comes back to the lab.

Where to send it, and what comes back

The note under the form's signature line: “Completed 116 applications must be sent to your local State Agency.” That is the agency for the state where the lab sits, found on CMS's State Agency contact list (updated May 2026), which gives each agency's address, phone and email. Ask the agency how it wants the form sent. A lab outside the U.S. emails CMS first to check its eligibility (see CMS's apply page).

  1. The State Agency processes the form.
  2. CMS emails a fee notice with your new CLIA number and the amount due: the certificate fee, plus the survey or validation fee where it applies. A compliance or accreditation applicant pays first for a registration certificate.
  3. You pay on pay.gov by bank account (ACH), debit or credit card.
  4. The certificate arrives by email after payment. You can begin testing once you receive it.

The CLIA number is ten characters. Under Claims Processing Manual Ch. 16, § 70.4: “Positions 1 and 2 contain the State code”, position 3 “contains the letter ‘D’”, and positions 4 to 10 are the number unique to your lab. The fee depends on your certificate and volume: see the CLIA fee calculator, and the full five steps in how to get a CLIA certificate.

Changes that need a new 116

CMS's CLIA brochure is explicit about one case: to change certificate type, you “reapply for the appropriate certificate using the same CLIA application (Form CMS-116)” and return it to the State Agency, and you cannot use the new type until you have paid any added fees and received the updated certificate. The other changes are notices with deadlines in 42 CFR 493. The form has boxes for them, but ask your State Agency whether it wants a full form or a letter.

Lab changes, the CLIA section that requires notice, the deadline and where it goes
ChangeRuleDeadlineOn the CMS-116, or where
Certificate type: a waiver or PPM lab adding tests its certificate does not cover§ 493.39, § 493.53Before the first test the current certificate does not coverChange in certificate type: a new CMS-116
Laboratory director§ 493.39, § 493.51, § 493.53, § 493.63Within 30 daysChange in laboratory director
Ownership, name or location§ 493.39, § 493.51, § 493.53, § 493.63Within 30 daysOther changes (specify)
Technical supervisor (high complexity, compliance)§ 493.51Within 30 daysAsk the State Agency
A new specialty or subspecialty (compliance or accreditation)§ 493.51, § 493.63No later than 6 months after the first testState Agency, or the accreditor for accredited labs
Test methods dropped or changed (compliance or accreditation)§ 493.51, § 493.63No later than 6 months afterState Agency, or the accreditor for accredited labs
Email address, or the lab stops testingCMS brochureWritten notice requestedOther changes (specify) for a closure

Takeaway

Adding a moderate complexity test to a waiver lab is the change that catches practices out: the notice is due before the first patient result, not after.

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