Much of the attention surrounding New York’s recent Medicaid enrollment changes has focused on the State’s temporary enrollment moratoriums and their potential effect on transactions. However, focusing only on which transactions may be delayed or affected by the moratorium misses more nuanced, but equally important developments in New York’s enrollment process.
Specifically, New York is changing how Medicaid provider enrollment information is submitted, reviewed and periodically revalidated. The State has transitioned from legacy paper-based enrollment and revalidation processes to the Provider Services Portal (“PSP”), while also implementing risk-based revalidation and temporary enrollment moratoriums for several provider categories.[1]
The Immediate Changes
New York Medicaid providers must now use the PSP for enrollment and revalidation. The PSP replaces the State’s legacy paper-based enrollment and revalidation process and provides a centralized platform for enrollment applications, changes of ownership, maintenance transactions and revalidation.[2]
The State is also implementing a risk-based, phased revalidation process. Providers are assigned to risk tiers that determine the applicable revalidation and screening requirements. High-risk providers generally revalidate every three years, moderate-risk providers every four years and limited-risk providers every five years.[3]
The accelerated revalidation initiative is being implemented in phases through June 2028. The initial phases include existing and newly designated high-risk providers, including certain Applied Behavior Analysis providers, Home and Community-Based Services providers and Licensed Home Care Services Agencies (“LHCSAs”), with other providers phased into the process thereafter.[4] The current phased initiative has a defined implementation period, but the obligation to maintain accurate Medicaid enrollment information and to revalidate is ongoing.[5]
Separately, New York has imposed temporary Medicaid enrollment moratoriums on six provider classes: laboratories; durable medical equipment, prosthetics, orthotics and supplies (“DMEPOS”) suppliers; Applied Behavior Analysis providers; LHCSAs; pharmacies; and Managed Long Term Care plans, including partial-capitation plans, Medicaid Advantage Plus plans and PACE organizations.[6]
For organizations contemplating acquisitions, affiliations, or restructurings, however, identifying whether a provider falls within a moratorium category is only the beginning of the analysis.
Revalidation Makes Enrollment Information an Ongoing Compliance Issue
Revalidation may ultimately prove as consequential as the moratorium itself. It creates a recurring point at which the State can compare the information reflected in a provider’s Medicaid enrollment record with the organization operating today. Revalidation is particularly important for organizations that have evolved through ownership changes, reorganizations, management changes, new service locations or other structural developments. Although New York Medicaid providers already have obligations to maintain accurate enrollment information and report specified changes, revalidation creates another point at which ownership, organizational information, managing employees, service locations and other enrollment information may receive regulatory scrutiny. Providers that fail to timely complete required revalidation may face termination from the Medicaid program.
Organizations preparing for revalidation therefore should not simply carry historical enrollment information forward, but rather should compare this information against current operations, with discrepancies evaluated under the applicable reporting and enrollment requirements.[7]
Takeaways
New York’s shift to the PSP and risk-based revalidation framework represents a fundamental change in how the State oversees Medicaid provider enrollment. Revalidation creates a recurring compliance obligation that requires providers to ensure their enrollment records accurately reflect current ownership, organizational structure, managing employees and service locations. Organizations that treat revalidation as a routine administrative exercise, rather than an opportunity to identify and address discrepancies, risk adverse consequences, including potential termination from the Medicaid program.
For organizations contemplating transactions, affiliations or restructurings involving New York Medicaid providers, these changes underscore the importance of addressing enrollment early in the planning process. Providers undergoing these changes should take a proactive approach by reviewing enrollment records against actual operations, evaluating the enrollment implications of any contemplated organizational changes and ensuring that Medicaid enrollment is treated as a core compliance function rather than a downstream filing concern.
FOOTNOTES
[1] N.Y. Dep’t of Health, NYS Medicaid Provider Revalidation (rev. Sept. 2026), https://www.health.ny.gov/health_care/medicaid/integrity/provider_revalidation.htm.
[2] Id.
[3] Id.
[4] Id.
[5] Id.
[6] Id.
[7] Id.