ABRAMS FENSTERMAN | CLIENT ALERT
New York Medicaid Enrollment Moratoriums:
Implications for Providers and Pending Transactions
By Ayman Soliman, Esq. and Violetta Mamonov, Esq.
On August 4, 2026, the New York State Department of Health (Department) announced temporary Medicaid enrollment moratoriums affecting laboratories; durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) providers; applied behavior analysis providers; licensed home care services agencies; pharmacies; and Managed Long Term Care plans. The moratoriums took effect on July 27, 2026.[1]
The Department confirmed that the moratoriums apply to new enrollments, reinstatements, and changes of ownership in the affected provider classes. All pending applications subject to the moratoriums will be discontinued, regardless of their stage of review. Applicants may submit new applications after the applicable moratorium ends, but discontinued applications will not automatically resume.[2] The initial six-month period runs through January 27, 2027, but the moratoriums may be extended in additional six-month periods. Accordingly, January 27, 2027 should not be treated as a confirmed reopening date.[3]
Medicaid Revalidation and the Provider Services Portal
The moratoriums are part of a broader effort to revalidate all Medicaid-enrolled providers by June 2028. Federal regulations require states to revalidate Medicaid providers at least once every five years, and the Centers for Medicare & Medicaid Services (CMS) has approved New York’s accelerated two-year revalidation plan.[4] New York has also transitioned to the Medicaid Provider Services Portal (PSP), which replaces the former paper-based enrollment and revalidation process. Since September 1, 2026, enrollment-related submissions, including revalidations and maintenance updates, must be made through the portal.[5]
Existing enrolled providers are not affected by the moratoriums solely because of their existing enrollment and may continue participating in Medicaid, provided they remain properly enrolled and comply with applicable requirements. Revalidations and most routine maintenance updates remain permissible.[6] Providers should ensure that their contact, ownership, licensing, service location, and National Provider Identifier (NPI) information is accurate and prepare to revalidate when notified. Providers may access the PSP using either an NY.gov ID Business account or a Health Commerce System account.[7]
Important Revalidation Deadlines
Providers should not begin revalidation until individually notified. Once notified, providers generally have 123 calendar days from the date of the initial notification letter to submit their revalidation. Failure to meet the applicable deadline will result in termination of Medicaid enrollment.[8] Providers who received duplicate initial revalidation notices during July, August, or September 2026 because of a system error may rely on the later-dated initial notice to determine their revalidation period.[9]
Implications for Healthcare Providers and Pending Transactions
For providers, investors, lenders, and transaction parties, the moratoriums may affect pending acquisitions, expansions, new service locations, and ownership changes involving affected enrollment applications. Importantly, the restrictions extend to change-of-ownership filings and are not limited to applications by entirely new providers. The impact of a particular transaction will depend on its structure, the provider class, and the specific enrollment and regulatory filings involved.[10] Parties should evaluate these issues before relying on a proposed closing date or Medicaid-related closing condition.
About the Authors |
Healthcare Regulatory & Transactional Counsel
Our firm advises healthcare providers, investors, lenders, buyers, and sellers on Medicaid enrollment, revalidation, ownership changes, regulatory approvals, and healthcare transactions. We can assist with reviewing provider records, preparing revalidation submissions, evaluating pending transactions, and addressing enrollment delays and related regulatory risk. Please contact Ayman Soliman, Esq. or Violetta Mamonov, Esq. at (516) 328-2300.
This client alert is for informational purposes only and is not legal advice.
Footnotes
[1] N.Y. State Dep’t of Health, New York State Department of Health Announces Improvements to Medicaid Provider Revalidation Process (Aug. 4, 2026), NYSDOH Release; N.Y. State Dep’t of Health, Office Hours with Medicaid’s Bureau of Provider Enrollment 13 (Oct. 1, 2026), Presentation.
[2] N.Y. State Dep’t of Health, NYS Medicaid Provider Revalidation (rev. Sept. 2026), NYSDOH Guidance.
[3] 42 C.F.R. § 455.470(c) (2026); Office Hours with Medicaid’s Bureau of Provider Enrollment, supra note 1, at 13.
[4] 42 C.F.R. § 455.414 (2026); New York State Department of Health Announces Improvements, supra note 1.
[5] eMedNY, Provider Service Portal (PSP) FAQs, QID P14 (updated Aug. 10, 2026), PSP FAQs.
[6] NYS Medicaid Provider Revalidation, supra note 2.
[7] eMedNY, What’s New in the PSP (updated Sept. 21, 2026), PSP Updates.
[8] NYS Medicaid Provider Revalidation, supra note 2.
[9] Provider Service Portal (PSP) FAQs, supra note 5, QID P15 (Oct. 6, 2026).
[10] NYS Medicaid Provider Revalidation, supra note 2.
