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HHS appeals judge: a late revalidation set the Medicare reactivation date at the day the application that was later processed to approval arrived

In decision CR7011, dated November 2, 2026, an administrative law judge found that CMS properly set October 11, 2024 as the effective date of reactivation of Medicare billing privileges for Caribbean Cancer Care Services LLC, a clinic/group practice with several practice locations in Puerto Rico. The contractor had told the practice in March 2024 to revalidate by June 30, 2024, and on July 3, 2024 notified the practice that a stay had been placed on its enrollment, during which claims are rejected. The revalidation application was received on October 11, 2024, and the judge held that the earliest possible effective date is the date the approved application was received.

Background

The decision is from the Civil Remedies Division of the HHS Departmental Appeals Board. In March 2024 a Medicare administrative contractor notified the practice that it was required to revalidate its Medicare enrollment record by June 30, 2024. The practice later requested a hearing before an administrative law judge to challenge the reactivation effective date that CMS determined.

Who this affects

Any Medicare-enrolled group practice, clinic or facility with a revalidation due date; provider enrollment and revenue cycle teams.

Why it matters

Inference: services furnished between the start of a stay or deactivation and the date of receipt of the revalidation application that is later processed to approval may not be billable. In this decision the appeal did not move the effective date earlier than the day that application was received.

Scope and timing

Authority status
Disposition
Responsible owner
Provider Enrollment; Revenue Cycle
Other dates
Revalidation due 2024-06-30; stay notice 2024-07-03; application received and reactivation effective 2024-10-11; decision dated 2026-11-02

Not established

Only the opening and the start of the background of the decision were read. Whether the enrollment was deactivated after the stay, and the dollar effect, were not read.

Sources

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