The New York State Department of Health (DOH) announced on August 5th that the Centers for Medicare & Medicaid Services (CMS) has approved the State’s plan to revalidate every Medicaid-enrolled provider by June 2028.

As part of this initiative, DOH is:

• Requiring all enrollment and revalidation activity to be completed through the new Provider Services Portal (PSP);
• Establishing risk-based revalidation and screening requirements;
• Requiring all enrolled providers to obtain a National Provider Identifier (NPI); and
• Temporarily halting new Medicaid enrollment for six provider classes.

The initiative applies across the Medicaid delivery system—including providers that bill Medicaid fee-for-service, participate only through Medicaid managed care, or appear on Medicaid claims as ordering, prescribing, referring or attending providers. Providers overseen by the Office for People with Developmental Disabilities (OPWDD), the Office of Mental Health (OMH) and the Office of Addiction Services and Supports (OASAS) are also subject to these requirements.

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Accelerated Revalidation Required by CMS

In April 2026, CMS directed states to adopt comprehensive strategies to revalidate their entire Medicaid provider populations within 24 months. CMS has approved New York’s plan to conduct the accelerated revalidation process in phases through June 2028.

DOH has emphasized that revalidation is a routine program-integrity requirement. Receipt of a revalidation notice—including under the accelerated schedule—does not indicate that a provider is suspected of fraud, wrongdoing or malfeasance.

According to State Medicaid Director Amir Bassiri, fewer than 10 percent of currently enrolled providers will experience a substantive change in the revalidation process. For more than 200,000 providers, the principal change will be the technology used to complete existing federal requirements.

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Who Must Enroll and Revalidate

Providers in enrollable categories of service must be enrolled in New York Medicaid if they:

• Bill Medicaid fee-for-service;
• Participate in a Medicaid managed care network and submit claims to a managed care plan; or
• Appear on Medicaid claims as ordering, prescribing, referring or attending providers.

All Medicaid-enrolled providers must complete revalidation when requested by the State, regardless of whether they serve fee-for-service members, managed care members or both.

Providers that do not complete revalidation by the deadline identified in their notice will have their Medicaid enrollment terminated.

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Provider Services Portal

All Medicaid enrollment and revalidation activity must now be completed through the Provider Services Portal (PSP), which replaces the State’s legacy paper-based process.

Providers must have an NY.gov business account, complete identity verification and establish access to the PSP. Through the portal, providers will submit or verify information concerning:

• Provider identity and credentials;
• Practice locations;
• Contact and correspondence information;
• National Provider Identifiers;
• Ownership and control; and
• Other documentation required for enrollment and screening.

Providers should not attempt to initiate revalidation until they receive an individual notice directing them to do so. Once notified, however, providers should respond promptly to avoid termination or a lapse in enrollment.

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Phased Revalidation Schedule

Phase 1 — Notifications Began in July 2026‍

The first phase includes:

• Providers currently designated as high risk;
• DMEPOS providers; and
• Providers that have not revalidated since the beginning of the COVID-19 public health emergency.

The regularly scheduled revalidation cycle for provider types not otherwise identified in the phased schedule is also expected to restart toward the end of Phase 1.

Phase 2 — Beginning Winter 2026

The second phase includes provider categories newly designated as high risk:

• Applied Behavior Analysis providers;
• Home and Community-Based Services providers operating under Section 1915(c) waivers; and
• Licensed Home Care Services Agencies.

Phase 3 — Early 2027‍

The third phase will include atypical providers currently enrolled without an NPI. These providers must obtain an NPI before completing revalidation.

Ongoing Phase — Through June 2028

All remaining moderate and limited-risk providers will be revalidated on a rolling basis through June 2028.

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Risk-Based Revalidation and Screening

Following the accelerated statewide initiative, providers will be assigned to one of three revalidation cycles:

• High-risk providers: Every three years;
• Moderate-risk providers: Every four years; and
• Limited-risk providers: Every five years.

All providers will be subject to identity and credential verification, confirmation of practice and contact information, NPI validation and submission of required documentation through the PSP.

Moderate-risk providers will also be subject to pre- or post-enrollment site visits. High-risk providers will be subject to site visits and fingerprint-based background checks for owners holding an ownership interest of 5 percent or more.

When a provider is also enrolled in Medicare, screening previously completed through Medicare may satisfy certain enhanced Medicaid screening requirements, including site visits or fingerprinting. Dually enrolled providers must nevertheless complete their New York Medicaid revalidation through the PSP.

Providers will be notified of their risk designation and applicable screening requirements when they receive their revalidation notice. A high-risk designation reflects the screening requirements assigned to a provider category or individual provider under federal and state criteria; it does not, standing alone, indicate suspected misconduct.

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National Provider Identifier Requirement

DOH will require all Medicaid-enrolled providers to have an NPI.

Providers currently enrolled without an NPI must obtain one before their next revalidation. A provider that does not obtain an NPI will be unable to complete revalidation and will have its Medicaid enrollment terminated.

Providers that do not currently have an NPI should begin the application process well in advance of their anticipated revalidation period.

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Transactions That May Satisfy Revalidation

Certain enrollment transactions require substantially the same information and screening as revalidation and may therefore satisfy a provider’s revalidation requirement. DOH indicates that the following transactions will generally qualify:

• A change of ownership;
• A reinstatement; or
• The addition of a category of service to an existing provider identification number.

DOH also anticipates that the upcoming PSP registration process will satisfy the revalidation requirement for many providers. When another transaction fulfills the applicable requirements, the provider may not receive a separate revalidation notice.

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Temporary Enrollment Moratorium

DOH has imposed an immediate temporary moratorium on new Medicaid provider enrollment for the following provider classes:

• Laboratories;
• Durable Medical Equipment, Prosthetics, Orthotics and Supplies providers;
• Applied Behavior Analysis providers;
• Licensed Home Care Services Agencies;
• Pharmacies; and
• Managed Long-Term Care plans, including partial-capitation plans, Medicaid Advantage Plus plans and Programs of All-Inclusive Care for the Elderly.

During the moratorium, all pending applications involving these provider classes will be discontinued immediately, regardless of their stage of review. This includes applications in initial submission, under active review or awaiting final determination.

Applicants may initiate or reinitiate an application after the moratorium concludes.

The moratorium does not terminate or suspend providers that are already enrolled in Medicaid. Existing providers in the six affected classes should continue serving Medicaid members and must complete revalidation when notified. The moratorium also does not affect providers applying to enroll in categories outside the six identified classes.

Providers with pending enrollment, reinstatement, change-of-ownership or category-of-service applications should confirm with DOH whether the transaction is affected.

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Recommended Immediate Steps

Medicaid providers should:

• Confirm that their email, correspondence and physical addresses are current;
• Establish and test access to the Provider Services Portal;
• Confirm that the appropriate staff have NY.gov business accounts and completed identity verification;
• Review enrollment, credential, practice-location and ownership information for accuracy;
• Confirm that all enrolled entities and practitioners have an NPI or have begun the NPI application process;
• Identify owners with an interest of 5 percent or more who may be subject to fingerprint-based screening;
• Monitor email and physical mail for an official revalidation notice; and
• Review the status of any pending application involving a provider class subject to the moratorium.

Providers should prepare the necessary information in advance but should wait for an individual notice before initiating revalidation through the PSP.

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DOH Webinar

DOH held a Medicaid Provider Revalidation webinar on Thursday, August 6, 2026, to provide additional information regarding the PSP, phased revalidation schedule, and new screening requirements. Slides from the webinar presentation can be viewed here.

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Additional information is available through the DOH Medicaid Provider Revalidation guidance, the DOH announcement and eMedNY’s revalidation resources.

Ostroff Associates will continue to monitor the implementation of the revalidation initiative, Provider Services Portal and enrollment moratorium and will provide additional updates as guidance becomes available.