All Texas Medicaid Providers Must Re-Enroll by June 17th…or Else!

April 28, 2016 | Spotlight



The Centers for Medicare and Medicaid Services (“CMS”) extended the original March 24, 2016 re-enrollment deadline to September 24, 2016. The consequence for failure to comply with this deadline is disenrollment, making the provider ineligible for reimbursement.

To avoid payment disruptions, Texas Medicaid requests all providers submit their re-enrollment applications on or before June 17, 2016. These providers will remain in Texas Medicaid even if the re-enrollment process is not complete by September 24, 2016 so long as the provider timely addresses deficiencies. Texas Medicaid, however, will not extend this courtesy to providers that submit applications after June 17, 2016. Instead, those providers will be disenrolled from Texas Medicaid, and suffer a gap in enrollment (and thus reimbursements) from September 25, 2016 to the date the application is finally approved. Even upon approval, a provider will not qualify for retroactive reimbursements.

Significantly, re-enrollment requires disclosure of whether the “legal entity [has] ever been sanctioned in any federal or state program,” including state administrative penalties. TMHP and DADS require disclosure of all sanctions incurred by the legal entity under the current ownership. This is in stark contrast to the current requirements that limit a provider’s obligation to keep records five (5) years. See, e.g., 15 TEX. ADMIN. CODE § 371.1719. Even though many providers will not have complete records to support the mandated disclosures, all providers should include information as far back as possible and then submit an explanatory statement for any deficient records.