What is Medicare Revalidation for Home Health & Hospice Providers?

Medicare revalidation is often a point of confusion for newer providers. Agencies owners often find themselves asking: 

• Is this the same thing as recertification?
• Didn’t we already do this when we enrolled?
• Why is CMS asking again if nothing has changed? 
• What actually happens if we miss something?

Part of the stress comes from the assumption that Medicare enrollment is a one-time event. Once certification is granted and billing is active, it’s easy to believe enrollment is complete. 

In reality, CMS treats enrollment as an ongoing obligation. When it’s misunderstood or deprioritized, agencies can experience billing holds, deactivation, or avoidable compliance risk.

*This article was written in consultation with Mariam Treystman.

At The Home Health Consultant, we work with Medicare-certified agencies nationwide on enrollment maintenance, compliance infrastructure, and survey readiness. We’re writing this article to clarify what Medicare revalidation actually is, how it differs from other Medicare requirements, and what happens if you miss the revalidation deadline.

What Does Medicare Revalidation Mean for Home Health and Hospice Agencies?

Medicare revalidation is CMS’s process for confirming that your agency’s enrollment information is accurate and current. 

During revalidation, CMS reviews the details already on file and requires agencies to attest to their accuracy or submit updates where changes have occurred.

For home health and hospice agencies, this typically includes verification including but not limited to:

• Legal business name and tax information
• Ownership and managing control details
• Practice and branch locations
• Authorized and delegated officials
• National Provider Identifier (NPI) data
• Licensure and certification status

Revalidation is a standard enrollment requirement. In most cases, it is not tied to wrongdoing or enforcement activity. Instead, it is CMS’s mechanism for ensuring that providers billing Medicare still meet enrollment requirements.

How Often Does Medicare Revalidation Occur for Home Health and Hospice Providers?

Most Medicare-participating providers, including home health and hospice agencies, are required to revalidate every five years. CMS assigns each provider a due date and publishes upcoming revalidation deadlines several months in advance.

CMS may also request an off-cycle revalidation, which occurs outside the routine schedule. Off-cycle requests can be triggered by reported changes, identified discrepancies, or complaints.

Regardless of timing, responding to revalidation is mandatory. There are no exemptions for Medicare-certified home health or hospice agencies.

CMS outlines these requirements on its official revalidation page. 

How Will a Home Health or Hospice Agency Know It’s Time to Revalidate?

Revalidation is administered through your Medicare Administrative Contractor (MAC). Agencies are typically notified by:

• Email
• U.S. postal mail
• Alerts or messages within PECOS

Notifications are usually sent three to four months before the assigned due date. However, agencies remain responsible for tracking their own deadlines, even if a notice is missed or overlooked.

CMS also publishes a public Medicare Revalidation List that allows agencies to confirm due dates in advance. Referencing this list on a regular basis is a best practice for enrollment oversight.

How Do Agencies Complete Medicare Revalidation?

CMS strongly encourages agencies to complete revalidation electronically through PECOS (Provider Enrollment, Chain, and Ownership System).

PECOS allows agencies to:

• Review enrollment data already on file

• Upload supporting documentation

• Electronically sign and submit applications
• Reduce delays associated with paper submissions

Because PECOS tailors applications to provider type, it helps limit unnecessary questions and reduces common submission errors.

Pro Tip: Your PECOS login information is the same as your NGS Connex login information. To learn how to set up your NGS Connex account, check out our explainer article below.

What Happens If CMS Requests Additional Information During Revalidation?

Revalidation is not always completed in a single submission. If your MAC identifies missing or inconsistent information, it may issue a request for additional documentation.

Agencies are typically given 30 days to respond. Failure to respond within that timeframe can result in:

• Temporary holds on Medicare payments
• Deactivation of Medicare billing privileges

This is a common risk point, and makes it especially important for your agency to stay on top of notifications from their MAC or Medicare.

Can CMS Conduct an On-Site Inspection as Part of Revalidation?

CMS or its contractors may conduct an on-site inspection during revalidation. They may do this to confirm:

• The physical location exists and is operational
• The address matches enrollment records
• The agency meets Medicare enrollment criteria

If CMS determines that enrollment requirements are not met, revalidation may be denied, and billing privileges may be suspended or revoked.

What Are the Consequences of Missing a Medicare Revalidation Deadline?

Failing to revalidate by the assigned due date can lead to serious operational consequences. These operational consequences can include but are not limited to:

• Holds on Medicare reimbursement
• Deactivation of Medicare billing privileges
• The need to submit a brand-new enrollment application

During a period of deactivation, Medicare will not reimburse claims, even if services were otherwise covered and properly delivered.

Again, CMS does not grant extensions for revalidation deadlines.

What Should Home Health and Hospice Agencies Prepare Before Revalidation?

Agencies that prepare in advance tend to experience fewer delays. Common preparation steps include:

• Confirming active PECOS access and user roles
• Reviewing ownership and management information
• Verifying addresses and practice locations
• Ensuring licensure and certifications are current
• Confirming banking and EFT information

Preparing this information before logging into PECOS helps reduce follow-up requests and submission errors.

How Else Should Home Health & Hospice Agencies Prepare to Meet Medicare Expectations?

Medicare revalidation is not the only thing your agency needs to stay on top of to maintain your enrollment. As all agencies know, you also need to complete your Medicare re-certification survey every three years. 

Agencies should have a clear understanding of how enrollment information is maintained, how changes are tracked and reported, and who is responsible for oversight. Understanding what Medicare expects is only one part of compliance; knowing how to communicate those expectations accurately matters just as much.

For your next read, check out our article explaining: How to Talk to Surveyors. In it, you’ll learn how to respond to enrollment and compliance questions without creating unnecessary risk.

*Disclaimer: The content provided in this article is not intended to be, nor should it be construed as, legal, financial, or professional advice. No consultant-client relationship is established by engaging with this content. You should seek the advice of a qualified attorney, financial advisor, or other professional regarding any legal or business matters. The consultant assumes no liability for any actions taken based on the information provided.