Miss Your Medicare Revalidation Date and the Weeks Before You Fix It Are Never Paid

Medicare enrollment is not permanent. Under 42 CFR 424.515, a physician, a group or another non-DMEPOS provider or supplier must resubmit and recertify its enrollment information every five years. DMEPOS suppliers do it every three years. CMS can also ask for an off-cycle revalidation at any time.

Most practices know this. The problem is that the notice usually goes to whoever was the contact person on the enrollment record years ago. That person may have left, or the email address may no longer be checked. The first sign of a problem is then a stop in Medicare payments.

States are tightening the same control on the Medicaid side. In October 2026, CMS published a framework of six program integrity pillars for Medicaid and CHIP. It calls provider enrollment the first line of defense and describes ongoing checks of providers and owners against exclusion, sanction and licensure sources. In April 2026, CMS also asked states to revalidate high-risk Medicaid providers off-cycle.

Why a late revalidation costs more than a late form

CMS says it does not grant extensions and there are no exemptions from revalidation. If you miss the due date, CMS warns of a hold on your Medicare payments or deactivation of your Medicare billing privileges.

The rule that matters most is in 42 CFR 424.540. A provider or supplier may not receive payment for services furnished while deactivated. When the enrollment is reactivated, the effective date is the date the Medicare contractor received the reactivation submission that it approved. It is not the date of deactivation. Any visits between the two dates stay unpaid.

Here is a hypothetical case. A three-physician group misses its due date because the notice went to a former office manager. Billing privileges are deactivated. Claims start to deny, and three weeks pass before someone traces the denials to enrollment. The group then submits its application, and the contractor approves it. Medicare pays from the date the contractor received that submission. The three weeks of Medicare visits before it are not payable.

Where to find your date

CMS posts revalidation due dates in the Medicare Revalidation List, seven months in advance. The Medicare enrollment contractor also sends a notice by email or U.S. mail about three to four months before the due date. When CMS asks you to revalidate, 42 CFR 424.515 gives you 60 calendar days to submit.

• Search the Medicare Revalidation List for the group's NPI and for every individual clinician who reassigns benefits to the group. Each enrollment has its own record.
• Write each due date in a shared calendar with a reminder 90 days before it.
• Sign in to PECOS and check who is listed as the contact person and correspondence address. Update it to someone who still works at the practice.
• Make one person responsible for opening mail and email from the Medicare contractor, and check that address every week.

What to check if payments stop

This is general information, not legal advice. If Medicare payments stop or claims start to deny for enrollment reasons, act on the same day:

• Call the Medicare contractor's provider enrollment line and ask for the status of each enrollment: active, on hold or deactivated, and the effective date.
• If an enrollment is deactivated, submit the reactivation or revalidation application through PECOS at once. Every day of delay is a day that Medicare does not pay.
• Hold Medicare claims for the affected clinicians instead of sending them into denials, and keep a list of every visit in the gap.
• Check Medicaid and Medicare Advantage enrollments at the same time. A state Medicaid revalidation request can arrive on its own schedule.

A small calendar that protects a large revenue line

Revalidation is a simple task with a high cost of failure. The fix is a list of every NPI, a due date for each, and a current contact person on every enrollment record. If you want to know where your practice stands, a revenue review can look at one payer's denials over the last 90 days and show whether any of them started with an enrollment problem.