Medicare Revalidation Checklist for Providers: What to Do Before Your Due Date

What Medicare Revalidation Actually Is

Medicare revalidation is the process by which CMS periodically requires every enrolled provider and supplier to resubmit and confirm their enrollment information. It is not optional, and it does not happen automatically — you are required to initiate and complete the process before your assigned due date or CMS will deactivate your billing privileges, effective the day the deadline passes. Unlike an initial enrollment, a revalidation deactivation can sometimes be reversed, but the process takes time and claims submitted during the gap are not payable retroactively for the deactivated period.

How to Find Your Revalidation Due Date

CMS posts revalidation due dates at pecos.cms.hhs.gov — look up your enrollment record by NPI. Due dates are also included on the 369 Revalidation Notice that CMS mails to your enrollment address of record; this is why keeping your address current in PECOS matters beyond just the surface-level accuracy concern. If no due date appears in your PECOS record, that typically means your revalidation window has not yet been assigned, not that you are exempt from the requirement.

Medicare Revalidation Checklist — Complete Step-by-Step

Work through the following in order. Steps marked (PECOS) apply to providers using the PECOS online system; steps marked (CMS 855) apply to paper filers, though online is strongly preferred.

Before You Start (2–4 Weeks Before Deadline)

  • Confirm your due date in PECOS and calendar a reminder 30 days before it.
  • Verify your enrollment address — CMS notices go to whatever address PECOS shows, not your practice address if different. Confirm it is current.
  • Confirm your surety bond is active (required for suppliers; verify amounts meet current CMS thresholds).
  • Gather current copies of all required attachments:
    • Medical license for every state where you bill Medicare (current, no restrictions)
    • DEA registration (if applicable — must match billing state)
    • Malpractice insurance certificate (current policy period, coverage amounts per CMS requirements)
    • Board certification certificates (if applicable to your enrollment type)
    • IRS CP-575 or 147-C letter confirming your EIN (required for group revalidations)
    • CLIA certificate (if billing lab services)
  • Check the OIG exclusion list (oig.hhs.gov/exclusions) for all providers and any owners, managing employees, or officers covered by the revalidation. Any exclusion must be resolved before submission.

During Submission (PECOS)

  • Log into PECOS (pecos.cms.hhs.gov) and initiate the revalidation from your enrollment record — do not start a new enrollment application by mistake.
  • Review and confirm all enrollment sections:
    • Individual provider information (name, NPI, SSN/EIN)
    • Practice location(s) — add, remove, or update as needed
    • Practice name and legal entity (if group)
    • Specialty and taxonomy code — verify this matches NPPES exactly
    • Billing MAC/jurisdiction
    • Reassignment of benefits (if relevant)
    • Adverse action disclosures — all felonies, license sanctions, or exclusions must be disclosed
  • Upload all required attachments directly in PECOS. Legibility matters — blurry or cropped documents are a common cause of Additional Documentation Requests that delay processing.
  • Review the certification page before submitting. Incorrect answers to the adverse action questions are treated as fraud, regardless of intent.
  • Submit and save the confirmation number. Track processing at pecos.cms.hhs.gov.

After Submission

  • Respond to any Additional Documentation Requests (ADRs) within 30 days — missing an ADR deadline after submission can result in rejection and require you to resubmit the entire application.
  • Monitor your PECOS record for status updates. CMS currently quotes 60–90 days for processing, though MAC-specific timelines vary.
  • Confirm your effective date and PTAN once the application is approved — your PTAN should remain the same on revalidation, but verify it matches your billing system.

Most Common Revalidation Errors

  • Taxonomy mismatch between PECOS and NPPES — the single most common cause of rejection. Your CMS-855 or PECOS taxonomy must match your NPI registry entry exactly.
  • Expired or incomplete malpractice certificate — the document must show the current policy period and coverage amounts; a certificate with a lapsed date is rejected even if you have current coverage.
  • Missing adverse action disclosures — providers who answer "no" to disclosure questions without checking state licensing board and court records create a falsification risk.
  • Submitting to the wrong MAC — your revalidation goes to the MAC that administers your billing jurisdiction, not necessarily the one serving your physical location.
  • Paper submissions instead of PECOS — CMS strongly prefers and in some cases requires PECOS. Paper forms process more slowly and have higher error rates.

What Happens If You Miss Your Deadline

CMS issues a deactivation that takes effect the day after the missed deadline — there is no grace period. Claims billed under a deactivated enrollment are not payable. To reactivate, you must submit a new enrollment application (not a revalidation) and go through the standard approval process, which currently averages 60–90 days. Revenue lost during the gap is not recoverable. This is why ProEnrollment recommends starting the revalidation process at least 60 days before the assigned due date, not 30.

How ProEnrollment Handles Revalidation

ProEnrollment's Medicare PECOS enrollment service manages revalidations as part of ongoing enrollment management — due dates are tracked and initiated proactively, not discovered when a deactivation notice arrives. Every revalidation passes the same 12-point pre-submission audit as initial applications, covering the taxonomy, licensure, malpractice, and disclosure items most likely to generate an ADR. If you have an upcoming revalidation and are not currently enrolled with ProEnrollment, a free consultation is the fastest way to assess your current status and timeline.

Medicare Revalidation FAQ

How often does Medicare revalidation happen?

CMS assigns revalidation cycles on a rolling basis, typically every 5 years for most provider types. The exact schedule is determined by CMS, not the provider, and is viewable in your PECOS record.

Do I revalidate separately for each practice location?

A group practice typically revalidates under a single enrollment that covers all locations, but each location listed must be current and accurate. Adding or removing locations is done as part of the revalidation process.

Can I bill Medicare while my revalidation is pending?

Yes — as long as you submit before your due date, your billing privileges remain active during processing. The risk is only if you miss the due date entirely and CMS deactivates the enrollment.

What if I receive a 369 Notice but my enrollment is still current?

A 369 Notice means your revalidation window has been assigned. Even if your information has not changed, you are still required to complete the revalidation process — you cannot simply certify that nothing has changed and skip submission.