NY Launches Statewide Medicaid Mandatory Provider Revalidation Initiative

The New York State Department of Health (DOH) has launched a major statewide effort to modernize Medicaid provider enrollment. Between now and June 2028, every Medicaid-enrolled provider, including Fee-for-Service, Managed Care, and OPRA providers, must revalidate their enrollment through the new digital Provider Services Portal (PSP).

Here is what your organization needs to know and do to prepare.

Which Providers Are Required to Revalidate?

The revalidation requirements apply broadly to providers enrolled in the New York Medicaid program, including providers participating in:

• Medicaid Fee-for-Service
• Medicaid Managed Care
• Ordering, Prescribing, Referring, and Attending (OPRA) services

Affected provider types include:

• Licensed Home Care Services Agencies (LHCSAs)
• Physician practices
• Home health agencies
• Durable Medical Equipment (DME) suppliers
• Pharmacies
• Behavioral health providers
• Therapy providers
• Hospitals and health systems

Even providers that exclusively treat Medicaid Managed Care members remain subject to New York’s enrollment and revalidation requirements.

What’s Changing? Risk-Based Revalidation

New York is phasing out paper submissions and moving to a digital, federal risk-based framework. Your risk tier determines how often you must revalidate and what screening you will undergo:

• Limited Risk (Every 5 Years): Requires standard credential and record verification.
• Moderate Risk (Every 4 Years): Requires standard verification plus site visits where applicable.
• High Risk (Every 3 Years): Requires enhanced screening, site visits, and fingerprint-based background checks for key owners.

Implementation Timeline

The DOH will issue official notices via email and U.S. mail ahead of your assigned window. The phased rollout is scheduled as follows:

• Phase 1 (July 2026): High-risk providers, DME suppliers, and providers who have not revalidated since the COVID-19 Public Health Emergency.
• Phase 2 (Winter 2026): Newly designated high-risk providers, ABA providers, HCBS providers, and Licensed Home Care Services Agencies (LHCSAs).
• Phase 3 (Early 2027): Providers currently enrolled without a National Provider Identifier (NPI).
• Through June 2028: All remaining moderate- and limited-risk providers.

How to Prepare

Do not wait for your official notice to arrive. Taking proactive steps today will prevent administrative bottlenecks later:

1. Update eMedNY Contact Details: Ensure your current mailing address and primary email address are correct in eMedNY so official notices reach you without delay.
2. Secure an NPI Immediately: If your practice is currently enrolled without an active National Provider Identifier (NPI), obtain one now. Revalidation cannot be completed in the PSP without a valid NPI.
3. Register & Familiarize with the PSP Portal: Ensure key administrative personnel have access to the new Provider Services Portal.
4. Audit Internal Documentation: Organize ownership structures, practice addresses, active licenses, and credentialing information – especially for entities with multi-site locations or complex ownership.

How Kahn Yuniver Law Can Help

Navigating state portal transitions and complex ownership disclosures can create operational friction. Kahn Yuniver Law regularly assists physician practices, home care agencies, health systems, and investors with:

• Medicaid enrollment, revalidation, and PSP portal submissions
• Ownership structure reviews and Change of Ownership (CHOW) compliance
• DOH regulatory audits and screening preparation

If you have questions about your risk tier, need assistance auditing your corporate records, or want to prepare your organization for upcoming revalidation, please contact our healthcare legal team.