Update: NYS DOH Clarifies Medicaid Enrollment Moratorium and Provider Revalidation Requirements

Following our July 31, 2026, legal alert, the New York State Department of Health (DOH) has issued additional guidance regarding the implementation of the six-month Medicaid enrollment moratorium for certain “high-risk” provider types.¹

Most notably, the DOH has confirmed that all pending enrollment applications for affected provider types will be discontinued immediately, regardless of their stage of review. 

What the Six-Month Medicaid Enrollment Moratorium Means for Affected Providers

1. Applications will not remain pending during the moratorium. 
2. Applicants will need to submit a new enrollment application once the moratorium is lifted.  
3. Existing Medicaid-enrolled providers are not affected by the moratorium and should continue to participate in the Medicaid program and complete revalidation when notified.

What Happens If a Provider Fails to Revalidate?

The guidance reiterates that providers who fail to timely complete required revalidation through the Provider Services Portal (PSP) will have their Medicaid enrollment terminated. The DOH emphasizes that revalidation is a routine federal program integrity requirement and does not indicate suspected fraud or wrongdoing.

I Still Have Questions About the Revalidation Process. What Should I Do?

The DOH will be hosting a New York State Medicaid Provider Revalidation webinar on August 6, 2026, from 3:00 to 4:00 p.m. EDT, to provide additional information regarding the revalidation process and implementation of these requirements. Click here to register.

Attorneys on Barclay Damon’s Health & Human Services Providers, Health Care Controversies, and Pharmacy Teams will continue to monitor developments and provide updates as additional guidance becomes available.

If you have questions about the content of this alert, please contact Brad Gallagher, co-leader of the Health Care Controversies and Pharmacy Teams, at bghallagher@barclaydamon.com, or another member of Barclay Damon’s Health & Human Services Providers, Health Care Controversies, or Pharmacy Teams.
                                                                                                           
¹NYS Medicaid Provider Revalidation