Notice of Off-Cycle Revalidation Initiative
The Missouri Medicaid Audit & Compliance (MMAC) Unit is issuing this notice to inform select providers of an upcoming, two-phased off-cycle provider revalidation initiative. This initiative is being undertaken in partnership with the Centers for Medicare & Medicaid Services (CMS) and in consultation with the Office of Governor Mike Kehoe and the MO HealthNet Division (MHD).
This revalidation effort follows Governor Kehoe’s recent communication with CMS regarding enhanced program integrity expectations and federal oversight activities. Governor Kehoe has conveyed Missouri’s commitment to an accelerated revalidation strategy of specific Medicaid provider types to ensure continued compliance with current federal and state screening, enrollment, and program requirements. This off-cycle revalidation process is a key component of that strategy and is intended to reduce fraud and strengthen program integrity.
What This Means for Providers
- MMAC has initiated a two-phase revalidation cycle for selected provider types and individual providers outside of the normal revalidation cycle.
- Providers selected for this off-cycle review will receive the standard 120-, 90-,60-, and 30-day letters via email at the address listed in their eMOMED account. It is the provider’s responsibility to ensure their eMOMED account contact information is up to date.
- If providers receive a revalidation letter(s) via email, they must revalidate prior to the deadline noted in the letter.
Failure to complete the required revalidation steps within the designated timeframe will result in administrative action, including termination as a provider from the MO HealthNet program.
Who Needs to Revalidate
Phase I:
- The following Provider Types shall revalidate prior to Oct. 1, 2026:
- Adult Day Care providers (Provider ID beginning with “29”)
- Durable Medical Equipment Suppliers (Provider ID beginning with “62”)
- Providers without NPIs,
- Any other provider identified as “high-risk” by CMS or MMAC.
- Includes Clinics (Provider ID beginning with “50”) with an Autism Center (Specialty code of “AC”)
- Timeline of events for Phase I:
- May 4 – May 30, 2026: Public Notice and educational campaign
- June 1 – Sept. 1, 2026: Monthly 120, 90, 60, 30-day revalidation notices sent to providers.
- October 1, 2026: Initiation of Administrative Action, including termination, for non-compliant providers.
Phase II:
- The following Provider Types shall revalidate prior to March 2, 2027:
- Home Health Agencies (Provider Type #s beginning with “58”)
- Private Duty Nursing (Provider Type #s beginning with “94”)
- Applied Behavioral Analysts (Provider Type #s beginning with “73”)
- Hospice (Provider Type #s beginning with “82”)
- Substance Abuse (Provider Type #s beginning with “86”)
- Timeline of events for Phase II:
- Oct. 1 – Oct. 31, 2026: Public Notice and educational campaign
- Nov. 1, 2026 – Feb. 1, 2027: Monthly 120, 90, 60, 30-day revalidation notices sent to providers.
- March 3, 2027: Initiation of Administrative Action, including termination, for non-compliant providers.
MMAC appreciates your cooperation and partnership as we implement these measures to safeguard the integrity of the MO HealthNet program and ensure continued compliance with CMS guidelines.
Learn More
If you have questions regarding this notice, please contact:
Missouri Medicaid Audit & Compliance (MMAC)
Provider Revalidation Unit
mmac.revalidation@dss.mo.gov
573-751-5238