NY Medicaid Revalidation and Enrollment Moratorium: Immediate Planning Considerations for Providers

New York Medicaid providers should prepare now for significant changes in provider enrollment oversight. The New York State Department of Health (DOH), following direction from the Centers for Medicare & Medicaid Services (CMS), will require every Medicaid-enrolled provider in New York to complete revalidation over the next 24 months. The process will require coordination among compliance, operations, billing, finance, governance, and transaction teams.

DOH will implement the State’s CMS-approved revalidation strategy through a phased schedule and the Provider Services Portal (PSP). Providers should expect electronic submission requirements, phased notices, detailed ownership and affiliation disclosures, and screening requirements.

DOH has also announced a six-month moratorium on new Medicaid provider enrollments for certain provider types. The moratorium may affect new enrollments, ownership changes, acquisitions, and other transactions involving affected provider types, making early planning important.

The key point for affected providers is that revalidation is not just a filing requirement. Providers will need accurate and current enrollment records, ownership and affiliation information, National Provider Identifiers (NPIs), PSP access, compliance documentation, and designated internal personnel responsible for Medicaid enrollment matters.

Revalidation Will Apply to Every New York Medicaid Provider

New York will revalidate all Medicaid providers in phases through June 2028 using the PSP, the State’s secure digital platform for enrollment and revalidation that has replaced the legacy paper-based process. The requirement applies broadly across the Medicaid delivery system, including fee-for-service providers, managed care network providers, and providers listed on claims as ordering, prescribing, referring, or attending providers. Although revalidation is a routine program-integrity process – not an indication of suspected fraud or wrongdoing – it will require providers to confirm that enrollment information, credentials, practice details, and required documentation remain accurate and compliant with federal and state requirements.

Providers should not attempt to revalidate until they receive an official notice. Notifications are expected to be sent by both email and U.S. mail and will include instructions for completing the process. Once notified, providers must complete revalidation within the required timeframe stated in the notice. Failure to respond or successfully complete revalidation may result in termination of Medicaid enrollment.

DOH’s current schedule began in July 2026 with current high-risk providers, durable medical equipment providers, and providers that have not revalidated since the start of the Covid-19 Public Health Emergency. Later phases are expected to include newly designated high-risk providers, atypical providers enrolled without an NPI, and remaining moderate- and limited-risk providers, with implementation continuing through June 2028.

Before receiving a revalidation notice, providers should confirm that the correct internal personnel are monitoring DOH and eMedNY communications, contact information is current, and responsibility for PSP submission and follow-up has been assigned.

High-Risk Providers Should Prepare for Enhanced Scrutiny

New York’s revalidation process designates certain providers as “high risk” for enrollment and screening purposes. This designation is not an indication of fraud or malfeasance, but it does mean affected providers should prepare for enhanced screening and more frequent revalidation. These “high risk” providers, including Applied Behavior Analysis (ABA), Home and Community-Based Services (HCBS) under a 1915(c) Waiver, and Licensed Home Care Services Agencies (LHCSAs), are included in Phase 2 of the rollout, scheduled to begin in winter 2026.

Providers that are unsure of their risk level should look to the revalidation notice, which DOH guidance indicates will identify the applicable designation and requirements.

Providers enrolled in Medicare may be able to satisfy certain screening requirements through existing Medicare enrollment, where permitted. Medicaid providers should nonetheless be prepared for additional documentation requests, site visits, ownership review, and risk-based monitoring if required.

Providers Should Confirm NPI Status Before Receiving a Revalidation Notice

Historically, some Medicaid provider types, including certain HCBS waiver providers, were permitted to enroll without an NPI. New York’s updated approach will require all Medicaid providers to obtain and maintain an active NPI before revalidation.

Providers should determine now whether each Medicaid enrollment has an active NPI. Organizations that do not have one should review the National Plan and Provider Enumeration System (NPPES) application process and begin gathering the information needed to avoid delays during revalidation.

PSP Access Should Be Treated as an Operational Readiness Item

The State has discontinued legacy paper-based enrollment and revalidation processes. Providers must use the DOH Provider Services Portal to manage enrollment and revalidation activity and should confirm NY.gov business account access, multi-factor authentication readiness, authority to claim and validate provider records, and procedures for responding to PSP-generated requests.

Because PSP readiness may involve operational, credentialing, compliance, and ownership personnel, providers should identify the responsible team now and verify that authorized users have the access needed to prepare, review, and submit materials.

Ownership and Affiliation Information Should Be Reviewed Now

During enrollment and revalidation, providers will be required to disclose ownership interests, managing employees, and affiliations with other Medicare, Medicaid, or CHIP providers that have experienced certain program integrity actions, including exclusions, payment suspensions, denied enrollments, or outstanding government debt.

Providers should begin reviewing corporate ownership structures, governance records, managing-employee information, and affiliation disclosures now. Inconsistent, incomplete, or outdated ownership records could delay revalidation, complicate transaction planning, or invite additional follow-up from the State.

The Enrollment Moratorium May Affect Transactions and Expansion Plans

New York has announced a six-month moratorium on new Medicaid provider enrollments for six high-risk provider categories: laboratories, durable medical equipment suppliers, applied behavior analysts, licensed home care services agencies, pharmacies, and managed long-term care plans. DOH has also identified other provider types, including 1915(c) waiver service providers, as categories that may receive heightened enrollment scrutiny or future program-integrity measures.

The moratorium is expected to be temporary and is intended to give the State time to implement its new revalidation process for currently enrolled providers. However, New York has previously extended formal and informal pauses on certain provider applications, including licensed home care services agency and hospice applications, so providers should not assume that all pauses will end precisely on the announced schedule.

Affected providers considering expansion, acquisition, affiliation, or restructuring should analyze Medicaid enrollment consequences before signing or closing. Stock transactions may preserve the existing enrolled entity but still require notice, review, or approval of ownership changes. Asset transactions may be more directly affected if the buyer or surviving entity needs a new Medicaid enrollment during the moratorium.

DOH confirmed during a Medicaid provider revalidation webinar earlier this month that changes in ownership will not be processed during the moratorium, although providers may be able to update technical data. Providers should account for that risk in letters of intent, purchase agreements, closing conditions, financing timelines, and operational transition plans.

Providers Should Expect Ongoing Monitoring Between Revalidations

Revalidation will no longer be the only point at which provider information is reviewed. The State will monitor providers continuously through automated data sources, including licensure, NPI records, exclusion databases, criminal-history information, business filings, ownership information, and Death Master File records. Material changes identified between revalidations may trigger an off-cycle review or revalidation.

Data Analytics Will Increasingly Inform Enforcement and Oversight

The State is expanding its use of advanced analytics to identify billing anomalies, unusual provider relationships, complaint trends, and other indicators of fraud, waste, or abuse. Over time, these tools may generate provider awareness letters, trigger targeted reviews, or result in additional monitoring based on dynamic risk scores.

Key Takeaways

Affected providers should begin preparing now by confirming active NPIs, assigning responsibility for PSP access and submissions, reviewing ownership and affiliation information, updating enrollment contacts, and strengthening compliance, billing documentation, and recordkeeping practices.

Providers involved in transactions should separately assess whether a proposed transaction would require a new Medicaid enrollment, whether DOH review of ownership changes may be delayed during the moratorium, and whether transaction documents and timelines adequately account for enrollment risk.

Taken together, the revalidation initiative, PSP implementation, enhanced screening expectations, continuous monitoring, and temporary enrollment moratorium reflect a broader shift toward more active, data-driven Medicaid enrollment oversight in New York. Providers that address these issues before receiving a revalidation notice will be better-positioned to complete revalidation efficiently, avoid enrollment disruption, and manage expansion or transaction plans during the moratorium.