On April 23, CMS Administrator Dr. Mehmet Oz posted on X that CMS had sent separate letters to states’ Medicaid Directors and governors. The letters ask states to take quick action on revalidation of high-risk providers in their Medicaid programs. CMS asks that:
1. Within 10 days of the receipt of the letter, states must inform CMS whether the state intends to carry out a "swift revalidation of high risk providers." The letter to governors notes that "failure to do so will be considered as we evaluate the likelihood of fraud in each state moving forward.
2. Within 30 days of the receipt of the letter, states must develop and submit a comprehensive two-year provider revalidation strategy. The strategy must include a description of the state ensures the accuracy of provider enrollment data through revalidation and other approaches. The letter to state Medicaid directors includes parameters to be included in the plans such as timelines, methodologies, data and information verification, and any necessary coordination with law enforcement.
CMS also says that states must submit their provider revalidation strategy results upon completion.
CMS notes that states have flexibility in determining what a "high risk provider" is but notes that providers with no National Provider Identification (NPI) number and those who have not been screened within the last 12 months are ones that states should consider for swift revalidation. CMS notes that states must include information on how they will assess provider enrollment for those without a NPI. Other letters from CMS to states like California have focused on home and community-based services providers including adult day, personal care, non-emergency transportation, and others, but the April 23 letters do not name any specific Medicaid service provider types as high risk (beyond a focus on those without NPIs).
A sample of the letter sent to governors can be found here. A sample of the letter sent to State Medicaid Directors can be found here. These samples are to the state of Alabama, but all states received these letters.
