CMS has gone quiet on individual Medicare revalidation

I was talking with a colleague recently about revalidations, and we kept circling the same oddity. Organizational revalidations are still moving through the normal cycle. Individual practitioners aren't getting letters, and their due dates aren't showing up. Neither of us could point to anything from CMS explaining it.

So I went looking for an explanation. There isn't a public one.

Is CMS revalidating individual practitioners right now?

Under 42 CFR 424.515, most providers have to resubmit and recertify their enrollment info every five years. But that clock doesn't start itself. CMS posts due dates to the Revalidation Due Date List, and your Medicare Administrative Contractor (MAC) sends a notice three to four months out. No listing, no notice, no obligation on the provider's end. That part is straightforward.

Can CMS change the revalidation schedule?

What's less straightforward is whether CMS can stop doing that for a whole category of providers without telling anyone. Technically, yes. Section 424.515(d)(2) lets CMS run revalidation less frequently for a provider type, but the stated basis is that the type's integrity and compliance justify it. If that's what happened here, CMS is within its authority.

Except the same subsection also requires CMS to give affected providers 90 days' notice before making that kind of change. I checked the CMS revalidation page, recent Medicare Learning Network (MLN) Connects issues, and MAC bulletins. As of October 2026, I couldn't find that notice.

For comparison, CMS knows how to do this the right way. When the skilled nursing facility (SNF) off-cycle revalidation deadline was suspended in December 2025, it was announced in an MLN Connects newsletter, with clear instructions on what SNFs should keep doing in the meantime. Public and actionable. None of that exists for individual practitioners. My bet is this is closer to an unadvertised backlog than a deliberate policy choice. Nothing about the manner suggests planning, and a backlog isn't among the grounds (d)(2) lists for changing the schedule. It looks like something got pushed down the list and never came back up.

Is my billing at risk?

None of this puts anyone's billing privileges at risk. You can't be deactivated under 424.540 for missing a due date CMS never assigned. If you're an individual practitioner worried about your own enrollment right now, this doesn't change your status.

What happens when revalidation restarts?

What suffers is the enrollment record itself. Revalidation is the mechanism that catches stale practice addresses, personal demographics, application contacts, and similar details in an individual's enrollment record. Leave it off for an entire provider class long enough and that data degrades. And whenever CMS turns it back on, however that happens, expect a mess. Compressed windows, applications bounced back for paperwork errors, MACs underwater. That's what followed past extension periods, and there's no reason to think this restart looks different.

What CMS owes providers

I don't think CMS owes anyone a restart tomorrow. I think it owes providers a sentence. Say what's happening. If (d)(2) justifies this, put that in writing and give the 90 days' notice, the way it announced the SNF change. If it's a backlog, say that instead. Either answer is workable. The current answer, nothing, isn't.

If you've seen a CMS notice on this that I missed, tell me. I'd rather be wrong about the silence than right about it.

About the author

Tony Kuka · Founder, Ziurta

Tony is the founder of Ziurta, a provider enrollment platform for medical practices, health systems, RCM firms, and credentialing companies. He has 30 years in healthcare administration, including 20 building outsourced revenue cycle companies, and founded and sold Medical Business Office and National Credentialing Solutions. He is based in Chattanooga, Tennessee.

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