Medicaid Provider Revalidation: Navigating Dr. Oz’s Sweeping Enrollment Audit
Published: April 27, 2026
On April 23, 2026, Dr. Mehmet Oz, Administrator of the Centers for Medicare & Medicaid Services (“CMS”), sent letters to all governors and State Medicaid Directors requesting that the states do the following:
- Within 10 days, provide to CMS a timeline for swift revalidation of high-risk providers. High risk providers include newly-enrolling home health agencies and durable medical equipment suppliers, as well as providers that have a history of certain fraud and abuse determinations or are in a category that has recently been the subject of a provider enrollment moratorium. Dr. Oz also indicated that states must designate that any provider without a national provider identifier as “high risk”; and
- Within 30 days, submit a comprehensive two-year provider revalidation strategy for off-cycle provider revalidations with a focus on high-risk providers.
Dr. Oz indicated in his letters that these steps are urgently necessary to ferret out corruption, fraud and waste.
What is Provider Enrollment?
Provider enrollment is the system by which providers apply to receive and maintain privileges to participate in the Medicaid program. Changes must be reported in California within 35 days of a change. Penalties for failure to timely or accurately report changes to the Medicaid enrollment system can include revocation of the provider enrollment, and reenrollment bars of one to ten years depending upon the circumstances.
Many providers are dependent upon Medicaid revenue because over twenty percent (20%) of the American population is on Medicaid.
What Challenges Do Providers Face When Submitting Revalidation Requests?
It is very easy for providers to have outdated or inaccurate information in their Medicaid enrollment files. This is because of the detailed nature of the information required to be submitted to State Medicaid Agencies, and challenges in interfacing with the Medicaid provider enrollment systems. In addition, revalidation requests by Medicare and Medicaid authorities in the past have been challenging for the following reasons:
- Sometimes the correspondence address is inaccurate in the provider enrollment records, meaning the provider does not actually receive the request for revalidation. So, the provider may not learn that it is subject to a revalidation request until their enrollment has been deactivated and funds are not flowing in.
- Sometimes the requests are not received by the provider for other reasons including issues with the Postal Service, complex organization mail room chaos, or what seems to be non-delivery of the communication by the agency sending out the communications.
- The requests for revalidation generally have a short time period for the provider to respond such as sixty (60) days. Given the complexity of a revalidation and the organizational structure of the provider, this may not be much time.
How Can Providers Mitigate Risk?
Providers can help lessen the potential risks of upcoming off-cycle revalidations by engaging in the following activities:
- Audit of Existing Medicaid Provider Enrollment File. An audit of the current Medicaid enrollment file can be undertaken now, and any errors or outdated information can be affirmatively fixed by reporting changes. While it is conceivable that the provider could receive a penalty for failure to report a change timely if it discovers an error, generally these kinds of self-reported fixes are processed by the Medicaid agencies without incident.
- Respond to Revalidation Requests Timely and With Serious Focus. The consequence of errors or omissions in responding to revalidation requests from the State Medicaid Agency is revocation of the Medicaid enrollment. Provider organizations should treat responding to the requests with the same diligence as filing a tax return or making a securities filing.
- Appeal Revalidation Denials. There is an appeal process for denials of Medicaid revalidation denials. This may be a good way to handle the many possible and excusable ways that a revalidation of a Medicaid provider enrollment may be denied. Those reasons might be administrative and clerical errors, timeliness delays that are not the fault of the provider, and disputes over whether the provider has in fact been legally compliant.
The Healthcare Team at Weintraub Tobin is well-versed in handling Medicaid enrollment matters of this sort. Please reach out to Jeanne Vance or any other member of the firm’s Healthcare Practice Group if we can be of assistance to your organization.