On November 4, 2026, the Centers for Medicare & Medicaid Services (“CMS”) issued the Calendar Year (“CY”) 2027 Home Health Prospective Payment System Final Rule (“Final Rule”). Although the Final Rule primarily addresses Medicare payment and policy requirements for home health agencies, CMS also finalized several changes to the Medicare provider enrollment requirements. CMS states that most of these new enrollment provisions apply to all provider types enrolled in the Medicare program, including skilled nursing facilities (“SNFs”).
Retroactive Revocations
CMS finalized a policy making all Medicare enrollment revocation grounds retroactive. Under the prior regulations, certain revocations were prospective and generally took effect 30 days after CMS or its contractor mailed the revocation notice, while other revocations were retroactive to the date the provider’s noncompliance began. Under the Final Rule, all revocation grounds will be retroactive. CMS states that this change will allow CMS to recover amounts paid to noncompliant providers.
The change means that a revocation may have an effective date that precedes the date the provider receives notice of the revocation, depending on the applicable regulatory ground and effective-date provision.
CMS Adds and Expands Grounds for Denial and Revocation
CMS also finalized new grounds for denial or revocation of Medicare enrollment and expanded several existing grounds.
Among the changes applicable across Medicare provider types, CMS expands its authority concerning certain program and license actions. Under the existing regulations, CMS may deny or revoke enrollment if a provider has a suspended or revoked license in another state or is suspended or revoked from Medicaid or another federal health care program. The Final Rule expands this authority to include similar actions involving the provider’s owners or managing employees or organizations.
CMS also finalized other additions and expansions to the grounds for Medicare enrollment denial and revocation, including provisions addressing false or misleading enrollment-related information and certain criminal conduct. CMS states that the finalized authorities are intended to address situations involving provider noncompliance and actual and potential fraud, waste and abuse, including improper activity by persons who own or operate Medicare providers.
Managing Employees
The Final Rule also revises provisions concerning individuals who qualify as “managing employees” for Medicare enrollment purposes. The Medicare enrollment regulations define a managing employee to include a general manager, business manager, administrator, director or other individual who exercises operational or managerial control over, or directly or indirectly conducts the day-to-day operations of, the provider or supplier. The Final Rule adds examples of clinical personnel that may meet the definition, including medical directors, clinical directors, departmental heads, supervising physicians, nursing directors and alternate administrators.
Additional Enrollment Changes
The Final Rule includes several other changes to Medicare enrollment requirements that may apply to SNFs and other Medicare providers.
For example, CMS finalizes changes concerning false or misleading information submitted in connection with Medicare enrollment. CMS expands the existing provision beyond information furnished on an enrollment application to include information submitted through other Medicare enrollment-related forms and documentation.
CMS also shortens the period available following a revocation for submitting certain outstanding claims. The existing 60-day period is shortened to 15 calendar days from the date of the revocation letter for claims for services furnished before the applicable revocation effective date, subject to the regulatory requirements and provider-specific provisions.
Practical Takeaways for SNFs
The Final Rule’s Medicare enrollment provisions provide an opportunity for SNFs to review their Medicare enrollment information and related compliance processes before the revised requirements take effect. SNFs should consider:
- Reviewing Medicare enrollment information for accuracy and completeness, including information concerning ownership and management;
- Reviewing individuals and organizations identified as managing employees, including whether clinical personnel exercise the level of operational or managerial control contemplated by the revised definition;
- Reviewing processes for Medicare enrollment changes and updates, particularly where changes involve ownership, management, licensure or other reportable information; and
- Promptly reviewing enrollment notices from CMS or its contractors, particularly given the Final Rule’s retroactive revocation provisions and shortened timeframe for submission of certain claims following revocation.
If you have questions about how these changes may affect your organization, please contact:
- Brian Jent at (317) 977-1402 or bjent@hallrender.com;
- Ellie Tucker at (314) 228-7508 or etucker@hallrender.com;
- Sean Fahey at (317) 977-1472 or sfahey@hallrender.com;
- Robert Markette at (317) 977-1454 or rmarkette@hallrender.com;
- Todd Selby at (317) 977-1440 or tselby@hallrender.com; or
- Your primary Hall Render contact.
Hall Render blog posts and articles are intended for informational purposes only. For ethical reasons, Hall Render attorneys cannot—outside of an attorney-client relationship—answer specific questions that would be legal advice.
