# Medicaid Revalidation for NEMT Providers in 2027: Deadlines, Steps, and Lapses

Canonical URL: https://nemtguide.com/guides/medicaid-revalidation/ · Updated 2026-09-29

Medicaid revalidation is the re-screening every state must run on each enrolled provider at least every five years under 42 CFR 455.414, and some states now revalidate NEMT companies sooner. When the notice comes, you update your owners, licenses, and insurance, pay any fee, and pass screening by the due date. Miss it and Medicaid, broker, and health plan payments stop.

- Federal rules require revalidation at least every five years. Arizona revalidates every four years, Minnesota revalidates NEMT every three, and North Dakota is moving NEMT to three.
- CMS asked every state on April 23, 2026 to quickly revalidate high-risk providers, so a notice can arrive before your usual date.
- The notice goes to the email and address on file, so keep your contact details current with the state.
- Missing the deadline stops Medicaid, broker, and health plan payments, and getting back in means applying as a new provider.
- Incomplete paperwork caused most of Minnesota's 2026 disenrollment notices, so keep ownership, license, and insurance records current all year.

Getting enrolled with Medicaid is not a one-time job. Every few years your state checks your company again from the start: who owns it, whether its licenses and insurance are current, and whether it still passes the screening for its risk level. That check is revalidation, and a missed deadline cuts off the trips you depend on.

2026 raised the stakes. On April 23, 2026, CMS asked every state to quickly revalidate providers at high risk of fraud, and states such as Minnesota and North Dakota have run off-cycle revalidations that include NEMT companies.

## What Medicaid revalidation is

Federal rule [42 CFR 455.414](https://www.ecfr.gov/current/title-42/section-455.414) requires every state Medicaid agency to revalidate the enrollment of all providers, of every type, at least every five years. CMS's Medicaid Provider Enrollment Compendium (last updated November 17, 2025) says states may revalidate more often and may order off-cycle revalidations, for example after complaints or signs of local fraud.

Revalidation is a full screening, not a form you sign. The compendium says the same risk-based screening that applies to a new provider applies at revalidation, along with the ownership and control disclosures. Under [42 CFR 455.104](https://www.ecfr.gov/current/title-42/section-455.104), those disclosures cover the name, address, date of birth, and Social Security number of every person with an ownership or control interest, and of every managing employee. The state also checks:

- **Licenses.** It confirms each license is current and has no limits, in other states too ([42 CFR 455.412](https://www.ecfr.gov/current/title-42/section-455.412)).
- **Federal databases.** It checks NPPES, the Social Security death file, and the federal exclusion lists, and runs the exclusion checks at least monthly ([42 CFR 455.436](https://www.ecfr.gov/current/title-42/section-455.436)). See the [OIG exclusion list](https://nemtguide.com/glossary/oig-exclusion-list/).
- **Site visits and fingerprints,** depending on your risk level (below).
- **The application fee,** when it applies to you.

It also reaches broker and health plan trips. The compendium says NEMT must be furnished by an enrolled provider, and under [42 CFR 438.602(b)](https://www.ecfr.gov/current/title-42/section-438.602), the state must screen, enroll, and periodically revalidate every network provider of its Medicaid health plans. For how enrollment works in the first place, see [how to become a Medicaid transportation provider](https://nemtguide.com/guides/how-to-become-a-medicaid-transportation-provider/).

### Your risk level decides the screening

| Risk level | What the state does at enrollment and revalidation |
|---|---|
| Limited | Checks that you meet federal and state rules for your provider type, verifies licenses, and runs federal database checks |
| Moderate | Everything above, plus site visits ([42 CFR 455.432](https://www.ecfr.gov/current/title-42/section-455.432)) |
| High | Everything above, plus a criminal background check and fingerprints from every owner of 5 percent or more ([42 CFR 455.434](https://www.ecfr.gov/current/title-42/section-455.434)) |

NEMT is a Medicaid-only provider type, so each state picks its risk level, as the compendium explains. The choices differ widely:

- **Florida** lists non-emergency transportation providers as limited risk (Enrollment Policy, February 2026).
- **Ohio** rates wheelchair van companies high risk at first enrollment and moderate at revalidation (appendix to rule 5160-1-17.8, in effect since January 31, 2020).
- **Minnesota** classifies NEMT as high risk, with background checks and site visits at enrollment and at revalidation every three years (state briefing of March 2, 2026).
- **North Dakota** named NEMT one of three service groups needing extra oversight in 2026, though not federally high risk, and added NPI, vehicle, insurance, driver, and site visit requirements.

Your level can also rise. The state must move you to high risk if it suspends your payments over a credible allegation of fraud, waste, or abuse, if you have an existing Medicaid overpayment, or if OIG or another state excluded you in the past 10 years ([42 CFR 455.450(e)](https://www.ecfr.gov/current/title-42/section-455.450)). Pennsylvania, for example, counts an unpaid overpayment above $1,500 that is more than 30 days old, unless you are appealing it or have an approved repayment plan. See Medicaid provider risk levels and [what to expect at a Medicaid site visit](https://nemtguide.com/guides/medicaid-site-visit/).

## How often NEMT providers revalidate, state by state

The five-year rule is a ceiling. Each state sets its own cycle, notice, and portal. These rules apply to companies enrolled with the state Medicaid agency:

| State | How often | Notice and filing window | If you miss it |
|---|---|---|---|
| Texas | Most providers every 5 years, some sooner based on risk | Your due date shows in PEMS. The online application opens 180 days before it, and notices go by email and to your dashboard. | Disenrolled from all Texas state health care programs, including Medicaid health plans. Claims and prior authorizations deny. (TMPPM, September 2026) |
| Florida | Every 5 years for non-institutional providers, which includes transportation companies | Renew by the expiration date on your provider agreement | No payment from Florida Medicaid or any Medicaid health plan (Enrollment Policy, February 2026) |
| Ohio | At least every 5 years, and when your risk level changes | ODM sends a notice 90 days before your agreement expires. Do not start before it arrives. | Denied and terminated 30 days after ODM mails a written notice, and ODM does not have to offer a hearing (OAC 5160-1-17.4) |
| Pennsylvania | Each service location every 5 years | File at least 60 days before the date shown in PROMISe | In the 2026 high-risk review, a location that misses its deadline is closed (Bulletin 99-26-06, August 21, 2026) |
| North Carolina | Every 5 years | An invitation in the NCTracks message inbox, then 70 days to finish. The state fee is $100. | Record suspended and claims pend after 5 p.m. on the due date. Errors after that end the enrollment. (NCTracks, revised June 15, 2026) |
| Arizona | Every 4 years, with off-cycle reviews possible | Dates show in APEP | You lose billing privileges. AHCCCS may consider a retroactive date case by case after a termination for missed revalidation. |
| New York | Every 3 years for high-risk providers, 4 for moderate, 5 for limited, with every provider revalidated by June 2028 | Wait for the letter by email and mail, then finish within 123 calendar days in the Provider Services Portal. Transportation companies also need a MAS revalidation letter, valid 90 days. | Enrollment is terminated, and MAS warns of removal from its transportation network (NY DOH, revised September 2026) |

California's DHCS also tells providers to wait for its notice before submitting a revalidation. If your state is not listed, its provider manual or enrollment portal shows your date. See our [state guides](https://nemtguide.com/states/).

New York's step is worth knowing. Medical Answering Services (MAS), New York's statewide Medicaid transportation broker, requires a MAS Transportation Provider Revalidation Application once you are notified. It then issues a MAS Provider Revalidation Letter, valid for 90 days, which you send to New York Medicaid with your revalidation application. See [Medical Answering Services](https://nemtguide.com/brokers/medical-answering-services/).

## The 2026 off-cycle revalidations

On April 23, 2026, CMS sent letters signed by Dr. Mehmet Oz to every governor and state Medicaid director. The letters asked states to:

1. Swiftly revalidate providers at high risk of waste, fraud, and abuse. States choose who is high risk, but CMS expects the group to include every provider without a National Provider Identifier.
2. Tell CMS within 10 business days whether they would, and on what timetable.
3. Send a two-year revalidation strategy within 30 days. CMS urged off-cycle or more frequent revalidation of high-risk provider types, and suggested putting high-risk providers not screened in the past 12 months first.

States are running off-cycle reviews on their own schedules. Minnesota's began in January 2026 under a corrective action plan with CMS, and the others followed the April letters:

| State | Who must revalidate | Deadline |
|---|---|---|
| Minnesota | Providers of 13 high-risk services, including NEMT | May 31, 2026 (completed) |
| North Dakota | NEMT providers, with agency drivers now enrolling too | Planned July 1 to October 1, 2026 |
| Missouri | Providers without NPIs, adult day care, DME suppliers, and others MMAC or CMS calls high risk | Before October 1, 2026 |
| Pennsylvania | Providers categorized as high risk | December 31, 2026 |
| New York | Every enrolled provider, in phases | June 2028 |

North Dakota's two-year plan shows where NEMT screening is heading. Starting July 1, 2026, every NEMT driver who works for an agency must get an NPI, enroll as an individual provider, and affiliate with the agency. Driver licenses, vehicle registrations, active insurance, and site visits are part of NEMT enrollment and revalidation, and NEMT moves from a five-year to a three-year cycle once the off-cycle review ends. The state also paused enrollment of new NEMT agencies statewide on June 11, 2026, for six months with possible six-month extensions. Agencies already enrolled are not affected.

If you do not have an NPI, get one now. The compendium says NEMT providers that meet the federal definition of a health care provider may obtain one. New York requires every enrolled provider to have an NPI before its next revalidation and terminates providers that do not get one. See [how to get an NPI number for NEMT](https://nemtguide.com/guides/how-to-get-an-npi-number-for-nemt/).

### What Minnesota's review shows

Minnesota's DHS started Minnesota Revalidate 2026 on January 26, 2026, under a CMS-approved corrective action plan. Every owner with 5 percent or more needed a fingerprint background study before submitting, and DHS made unannounced visits to provider locations. Its June 4, 2026 results for the 5,583 high-risk providers it reviewed:

| Result | Providers |
|---|---|
| Revalidated and still serving members | 2,061 |
| Told they will be disenrolled | 3,411 |
| Of those, incomplete paperwork or documentation | 2,491 |
| Of those, failed verification at a site visit | 916 |
| Of those, failed a background study | 4 |
| Removed from review, no longer providing a high-risk service | 111 |
| Referred to the DHS Office of Inspector General | 59 |

DHS listed the common reasons: not disclosing who has management authority or not reporting a change in ownership, not reporting changes in or keeping credentials such as liability insurance and surety bonds, not giving access, and incomplete applications. Payments stopped when a disenrollment notice went out, and providers had 60 days to appeal. Most of the notices came from incomplete paperwork.

## What you need to revalidate

Gather these before the notice arrives:

| Item | Why the state asks |
|---|---|
| Legal name, EIN, NPI, and taxonomy, matching your IRS and NPPES records | The state checks NPPES and other federal databases |
| Name, address, date of birth, and Social Security number of every owner, officer, director, and managing employee | Required disclosures under 42 CFR 455.104 |
| Any family ties among owners, and other companies your owners hold | Also required under 42 CFR 455.104 |
| Current business, transportation, and local licenses and permits | The state verifies each license (42 CFR 455.412) |
| Liability insurance, and a surety bond where your state requires one | Florida requires $100,000 per person and $200,000 per incident, plus a surety bond for non-emergency, multi-load, and taxicab providers not contracted through the transportation coordinator |
| Vehicle list, registrations, and insurance cards | North Dakota asks for them on its NEMT enrollment and revalidation forms |
| Driver roster with license numbers | North Dakota asks for driver license copies, and agency drivers now enroll themselves. Minnesota's 2026 review asked providers to show the required qualified staff were in place. |
| Fingerprints for each 5 percent owner, if you are high risk | Due within 30 days of the request (42 CFR 455.434) |
| The application fee, or proof you are exempt | $750 in 2026 (42 CFR 455.460) |
| Any broker letter your state requires | New York requires the MAS revalidation letter |
| An office ready for an unannounced visit | Moderate and high risk bring site visits, and every enrolled provider must allow unannounced inspections (42 CFR 455.432) |

The [NEMT credentialing checklist](https://nemtguide.com/templates/nemt-credentialing-checklist/) covers many of the same documents, and your broker will ask for them too.

### What it costs

The federal application fee is $750 for applications submitted from January 1 to December 31, 2026, per the CMS notice of December 3, 2025. States must collect it from institutional providers at enrollment and revalidation. The compendium says CMS told states in 2011 that this includes non-emergency transportation providers billing fee-for-service. You do not pay it if you are enrolled in Medicare or another state's Medicaid program, or if you already paid it there. New York takes hardship waiver requests, which it sends to CMS for review. North Carolina adds its own $100 fee. CMS sets a new federal fee for each calendar year, so check the amount before you file on or after January 1, 2027.

## How to revalidate without a lapse

1. **Find your due date now.** Look it up in your state portal, such as PEMS in Texas, PROMISe in Pennsylvania, APEP in Arizona, or North Carolina's monthly reverification report. In Florida, it is the expiration date on your provider agreement.
2. **Keep your contact details current.** Notices go to the email and address on file. Missouri emails the address in your eMOMED account, and Pennsylvania uses the email on your provider file. Florida requires contact changes in writing within 30 days.
3. **Report changes as they happen.** New owners must be disclosed within 35 days of a change (42 CFR 455.104), and NPPES must be updated within 30 days (45 CFR 162.410). Unreported ownership and management changes were among the most common reasons for Minnesota's 2026 disenrollment notices. See [how to report changes to Medicaid](https://nemtguide.com/guides/report-changes-to-medicaid/).
4. **Start the day the notice arrives.** Where your state says to wait for it, as Ohio, New York, and California do, do not file early. Where the window opens early, as Texas's does 180 days out, use it.
5. **Build your packet** from the checklist above, and confirm every name and number matches your IRS letter and NPPES record.
6. **Pay the fee or claim the exemption** in the application.
7. **Answer every request fast.** Texas does not count a revalidation as done until every deficiency is fixed. North Carolina does not allow corrections after you submit, so check the application twice.
8. **Be ready for a site visit.** Keep the office open during posted hours, with records and vehicles available.
9. **Confirm the approval and your new date,** then send proof to each broker and health plan. Their own credentialing is separate. See [NEMT recredentialing](https://nemtguide.com/guides/nemt-recredentialing/).
10. **Put the next due date on your calendar** with a reminder six months ahead, using a NEMT compliance calendar.

## What happens if you miss the deadline

Payment stops first. The compendium says providers that miss their due date should not be paid for the gap between that date and the completed screening, because those payments could be counted as improper in a federal payment review.

Getting back in is a new enrollment. The compendium says a reenrollment follows the same steps as a brand new one, and a reactivated enrollment requires new screening and the application fee ([42 CFR 455.420](https://www.ecfr.gov/current/title-42/section-455.420)). Three more risks follow:

- **Broker and health plan trips stop too.** Health plans may contract with a provider pending state enrollment for only up to 120 days, and must end the contract when the state says the provider cannot be enrolled ([42 CFR 438.602(b)(2)](https://www.ecfr.gov/current/title-42/section-438.602)). North Carolina's termination reaches all of its health department's plans.
- **A moratorium can keep you out.** States can pause new enrollments of a provider type. Minnesota's pause on new NEMT providers in the seven-county metro runs to January 27, 2027, and North Dakota paused new NEMT agencies statewide on June 11, 2026, for six months at a time. Because reenrollment counts as a new enrollment, a lapse in those areas could keep you out until the pause ends. See [Minnesota's NEMT enrollment moratorium](https://nemtguide.com/news/minnesota-metro-nemt-enrollment-freeze/) and enrollment moratorium.
- **Appeal rights are limited.** Federal rules give terminated providers whatever appeal rights state law provides ([42 CFR 455.422](https://www.ecfr.gov/current/title-42/section-455.422)). Minnesota gave 60 days from the disenrollment letter. Ohio does not have to give a hearing when it ends an agreement for failure to file a revalidation.

If you are close to the deadline, file anyway and call the enrollment help line. In Texas, a request submitted before the due date and approved within 45 days after it has no gap. In Ohio, a provider that filed on time keeps operating under the expired agreement until the state decides.

## Revalidation, recredentialing, and change reports

Three processes keep you eligible, and each runs on its own clock:

| Process | Who runs it | When | What it checks |
|---|---|---|---|
| Medicaid revalidation | Your state Medicaid agency | At least every 5 years, often sooner for NEMT | Full screening at your risk level |
| Broker or plan recredentialing | Each broker and health plan | Set by each contract | Insurance, vehicles, drivers, and contract terms. See [NEMT broker credentialing](https://nemtguide.com/guides/nemt-broker-credentialing/). |
| Change reports | You | Ownership changes within 35 days; NPPES updates within 30 days; other deadlines set by your state | Owners, managers, addresses, bank accounts, and licenses |

Keep all three current and revalidation becomes a review of records you already maintain.

## Frequently asked questions

### How often do NEMT providers have to revalidate with Medicaid?

At least every five years. Federal rule 42 CFR 455.414 requires each state to revalidate every enrolled provider on that schedule, and states may do it more often. As of September 2026, Arizona revalidates every four years, Minnesota revalidates NEMT companies every three years as a high-risk provider type, North Dakota is moving NEMT to a three-year cycle, and New York revalidates high-risk providers every three years and moderate-risk every four. States can also start an off-cycle revalidation at any time.

### When will my state send the revalidation notice?

It depends on the state. Ohio's rule sets a notice 90 days before your agreement expires. North Carolina gives 70 days from its invitation, and New York gives 123 calendar days from its first letter. Pennsylvania sends 90-day and 30-day notices in its 2026 high-risk review and asks you to file at least 60 days before your date. Missouri's 2026 off-cycle review sent notices at 120, 90, 60, and 30 days. Texas opens the application 180 days before your due date.

### Do I have to revalidate if I only take broker or health plan trips?

Usually yes, if you are enrolled with the state. Federal rule 42 CFR 438.602(b) requires states to screen, enroll, and periodically revalidate every network provider of their Medicaid health plans. A lapse reaches those trips too. Texas disenrolls a provider that misses its date from its Medicaid health plans, Florida makes a provider that fails to renew ineligible for payment from any Medicaid health plan, and New York says providers serving only health plan members must revalidate too.

### How much does Medicaid revalidation cost?

The federal application fee is $750 for enrollments and revalidations submitted in calendar year 2026. States must collect it from institutional providers, and CMS has told states that includes non-emergency transportation providers billing fee-for-service. It is waived if you are enrolled in Medicare or another state's Medicaid program, or paid the fee there. Some states add their own fee, such as North Carolina's $100.

### What happens if I miss my revalidation deadline?

Payments stop, and getting back in means a new enrollment. CMS says a provider that misses its due date should not be paid for the gap until screening is complete, and a reenrollment follows the same steps as a new one, with a new fee. Texas denies claims after disenrollment, North Carolina suspends the record and pends claims, and Ohio terminates the agreement 30 days after mailing a notice.

### Why did I get a revalidation notice early in 2026?

On April 23, 2026, CMS asked every governor and state Medicaid director to swiftly revalidate providers at high risk of fraud, and said it expects each state's high-risk group to include every provider without a National Provider Identifier. States answered with off-cycle reviews, such as Minnesota's, which covered NEMT and ended May 31, 2026, and North Dakota's NEMT revalidation, planned for July to October 2026.

### Can I keep billing while my revalidation is pending?

In some states, yes, if you filed on time. Texas lets revalidating providers keep filing claims, and a request filed before the due date that is approved within its 45-day grace period has no gap. In Ohio, a provider that files on time may keep operating under the expired agreement until the state decides. File early so the review finishes before your date.

## Official resources

- [CMS: Medicaid Provider Enrollment Compendium](https://www.medicaid.gov/medicaid/program-integrity/downloads/mpec.pdf)
- [eCFR: 42 CFR 455 Subpart E, Provider screening and enrollment](https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-C/part-455/subpart-E)
- [CMS: NPPES, apply for or update an NPI](https://nppes.cms.hhs.gov/)
- [Texas: TMHP provider enrollment](https://www.tmhp.com/topics/provider-enrollment)
- [NCTracks: Provider re-verification](https://www.nctracks.nc.gov/content/public/providers/provider-recredentialing.html)
- [AHCCCS: Provider enrollment and revalidations](https://www.azahcccs.gov/APEP)
- [eMedNY: Revalidation information](https://www.emedny.org/info/ProviderEnrollment/revalidation/)
- [New York DOH: NYS Medicaid Provider Revalidation](https://www.health.ny.gov/health_care/medicaid/integrity/provider_revalidation.htm)