MMAC High-Risk Provider Revalidation FAQ

Frequently Asked Questions

What is the Off‑Cycle Revalidation Initiative? 

What is the Off‑Cycle Revalidation Initiative? 

Missouri Medicaid Audit & Compliance (MMAC), in partnership with Centers for Medicare and Medicaid Services (CMS) and in consultation with Governor Mike Kehoe’s Office and MO HealthNet Division (MHD), is launching a two‑phased, off‑cycle revalidation process for selected Medicaid providers to strengthen program integrity and meet federal oversight expectations

Why is Missouri doing this now? 

Why is Missouri doing this now? 

Governor Kehoe communicated Missouri’s commitment to enhanced program integrity and an accelerated revalidation strategy to ensure continued compliance with federal and state enrollment requirements. This initiative is intended to reduce fraud and protect MO HealthNet resources.

Which providers must revalidate?

Which providers must revalidate?

Phase I – Deadline: October 1, 2026

• Adult Day Care (ID begins “29”)
• Durable Medical Equipment (DME) suppliers (ID “62”)
• Providers without NPIs
• Any provider identified as “high‑risk” by CMS or MMAC
• Clinics (ID “50”) with Autism Center specialty code “AC”

Phase II – Deadline: March 2, 2027

• Home Health Agencies (ID “58”)
• Private Duty Nursing (“94”)
• Applied Behavioral Analysts (“73”)
• Hospice (“82”)
• Substance Abuse (“86”)

What is the timeline for Phase I?

Phase I

• Adult Day Care (ID begins “29”)
• Durable Medical Equipment (DME) suppliers (ID “62”)
• Providers without NPIs
• Any provider identified as “high‑risk” by CMS or MMAC
• Clinics (ID “50”) with Autism Center specialty code “AC”

Phase I Timeline:
• May 4 – May 30, 2026: Public notice & education
• June 1 – Sept 1, 2026: 120/90/60/30‑day notices
• Oct 1, 2026: Administrative action (including termination) for non‑compliance

What is the timeline for Phase II?

Phase II 

• Home Health Agencies (ID “58”)
• Private Duty Nursing (“94”)
• Applied Behavioral Analysts (“73”)
• Hospice (“82”)
• Substance Abuse (“86”)

Phase II Timeline:
• Oct 1 – Oct 31, 2026: Public notice & education
• Nov 1, 2026 – Feb 1, 2027: 120/90/60/30‑day notices
• Mar 3, 2027: Administrative action for non‑compliance

How will providers be notified?

How will providers be notified?

Providers will receive the standard 120-, 90-, 60-, and 30‑day email notices at the email address listed in their eMOMED account. Providers are responsible for keeping their contact information up to date.

How do I know if I’ve been selected for off-cycle revalidation?

How do I know if I’ve been selected for off-cycle revalidation?

If you receive a 120/90/60/30‑day email notice, your provider type has been selected. Notices go strictly to the email in eMOMED.

How do we start the revalidation process?

How do we start the revalidation process?

Instructions are included in the emailed notices. Providers should follow the steps exactly as outlined.

What happens if an organization never receives the email?

What happens if an organization never receives the email?

MMAC uses the email listed in eMOMED. It is the provider’s responsibility to maintain accurate contact information. Failure to update contact info does not exempt the provider from revalidation requirements. 

What do providers need to do? 

What do providers need to do? 

If a provider receives a revalidation letter, they must complete the entire revalidation process before the deadline stated in the notice. 

Can we request an extension?

Can we request an extension?

Extensions are not guaranteed. Providers should begin revalidation immediately upon receiving their first notice. 

What happens if a provider doesn’t revalidate?

What happens if a provider doesn’t revalidate?

Failure to complete revalidation on time will result in administrative action, including termination from the MO HealthNet program. 

Who can providers contact for help?

Who can providers contact for help?

MMAC Provider Revalidation Unit
Email: mmac.revalidation@dss.mo.gov
Phone: 573-751-5238

What counts as a “high-risk” provider? 

What counts as a “high-risk” provider? 

Providers are identified by CMS or MMAC as high-risk due to federal screening rules, program integrity concerns, or specific provider-type risk categories. 

What if we already revalidated recently?

What if we already revalidated recently?

If providers are newly enrolled or revalidated within the last 12 months, then they do not need to be revalidated.  Off-cycle revalidation is required due to Missouri’s accelerated revalidation strategy. This initiative is separate from the regular five-year cycle. It applies even if the provider recently completed their regular cycle. 

Will termination affect payments?

Will termination affect payments?

Yes. Termination from MO HealthNet stops all claims payment, and reinstatement requires re-enrollment. 

Does this apply to managed care network providers?

Does this apply to managed care network providers?

Yes. Providers must maintain state Medicaid enrollment even if in a managed care organization

Which provider types will have to pay a fee to revalidate?

Which provider types will have to pay a fee to revalidate?

Review the Quick Glance in the MO HealthNet Enrollment Guide. You can view a list of each provider type and if there is a fee.