Medicaid revalidation for transportation providers: renewal cycles, notices, and reporting changes
Revalidation is the periodic re-screening every Medicaid provider must pass to keep billing. The federal floor is one revalidation per provider every five years, and some states use shorter cycles, such as four years in Arizona. Several states began early revalidations in 2026. Missing the deadline gets a company disenrolled, and Medicaid health plans must end contracts with providers the state has not enrolled.
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Your Medicaid enrollment has an expiration date. Every provider has to be screened again on a set schedule, and a transportation company that misses its date can lose every Medicaid trip at once, including the ones that come through brokers. This guide covers the federal rule, how often states revalidate transportation providers, the early revalidations several states started in 2026, what the review checks, the fee, and the changes you must report in between, as of September 2026.
How revalidation works
Revalidation is a fresh screening of an enrolled provider. Under federal rules, each state Medicaid agency must revalidate all providers, of any type, no less than once in five years (42 CFR 455.414). A state can choose a shorter cycle.
CMS guidance treats revalidation as a full screening at the provider’s current risk level. It repeats the ownership and control disclosures and, at higher risk levels, adds a site visit and fingerprinting. States choose how it works in practice: paper or online forms, applications filled in ahead of time, and any method of notifying providers.
Revalidation also governs broker work. States must run the same screening and revalidation for providers in their Medicaid health plans’ networks (42 CFR 438.602), and a transportation company that contracts with a plan’s broker counts as a network provider (42 CFR 438.2). A plan can contract with a provider for one 120-day period while its enrollment is pending, and must terminate that provider immediately once the state reports that enrollment is not possible. A lapsed state enrollment puts your broker contracts at risk too.
This is separate from broker recredentialing, which follows your broker contract. You need both.
How often states revalidate transportation providers
Five years is only the federal maximum, and each state picks its own schedule. Six states illustrate the spread:
| State | Cycle | How notice works | What a miss costs |
|---|---|---|---|
| Texas | Five years for most providers; shorter for some, based on risk | The due date shows in the state enrollment system; revalidation opens 180 days before it | Automatic disenrollment on the due date unless a submitted request is completed within a 45-day grace period |
| Florida | Five years for non-institutional providers, the agreement transportation providers sign; three years for institutional providers | Renewal due by the agreement’s expiration date | No payment from fee-for-service Medicaid or Medicaid health plans |
| Ohio | No later than five years after the last agreement | A notice 90 days before expiration; providers may not start before it arrives | Denial and termination 30 days after written notice, with no hearing rights |
| Arizona | Every four years | Dates shown in the state provider enrollment portal | Loss of Medicaid billing privileges |
| New York | Three years for high risk, four for moderate, five for limited | Notice by email and mail, then 123 days to finish | Termination of enrollment |
| North Dakota | Moving NEMT to three years after its 2026 to 2028 review | Advance notice of a randomly assigned due date | Termination |
Sources: Texas Medicaid Provider Procedures Manual, Florida AHCA enrollment policy, Ohio Administrative Code 5160-1-17.4, AHCCCS, New York DOH, and North Dakota Medicaid.
New York’s timeline is the most detailed. After the first notice, a reminder follows 60 days later. Thirty days after that comes a notice of termination effective in 33 days, which is withdrawn if you submit before the termination date. In Ohio, a timely filer can keep working under the lapsed agreement until the department rules.
Accelerated revalidations from 2026
Many providers will revalidate ahead of schedule in 2026 and 2027. New York’s health department says CMS directed every state in April 2026 to adopt revalidation strategies that revalidate every Medicaid-enrolled provider over the next 24 months. Each state is handling it differently.
- New York is revalidating all providers by June 2028 in phases. High-risk providers and providers that had not revalidated since the start of the COVID-19 public health emergency got notices from July 2026, and providers enrolled without an NPI are scheduled for early 2027. Every provider needs an NPI to complete revalidation, and since May 2026 all revalidations go through the state’s online Provider Services Portal instead of paper.
- North Dakota submitted a two-year plan naming NEMT as one of three service categories needing extra oversight. It planned NEMT revalidation for July 1 through October 1, 2026, starting with providers without NPIs, providers under investigation, and providers with known compliance problems. The plan adds NPIs for the agency and for each employed driver, who must also enroll as an individual provider linked to the agency, along with proof of vehicle registration and active insurance, driver requirements, site visits, and a three-year cycle.
- Moratoriums. North Dakota paused new NEMT agency enrollments across the state from June 11, 2026, for a first term of six months that can be extended. Minnesota’s pause covers NEMT applicants based in the seven-county metro area (the counties of Anoka, Carver, Dakota, Hennepin, Ramsey, Scott, and Washington) from January 27, 2026, now extended to January 27, 2027. Under federal rules, the first term of a state moratorium is six months, and each renewal adds another six (42 CFR 455.470).
CMS already lets states call off-cycle revalidations for reasons such as random checks, signs of local fraud problems, national initiatives, and complaints. New York tells providers that an early notice is routine and does not mean anyone suspects them of wrongdoing.
What the review checks
What gets checked follows the risk category your state gives transportation providers (42 CFR 455.450). NEMT is recognized by Medicaid but not by Medicare, so CMS lets each state pick the level. Florida, for example, puts non-emergency transportation companies in its limited tier and ambulance services in moderate.
| Risk tier | What the state checks |
|---|---|
| Limited | Proof the company satisfies federal and state requirements, license verification, and federal database searches |
| Moderate | All limited checks, plus a site visit |
| High | Everything above, plus criminal background checks with fingerprints for anyone owning 5% or more |
The databases are NPPES, Social Security’s Death Master File, the Excluded Parties List System, and the OIG’s List of Excluded Individuals/Entities. States have to rerun the exclusion searches every month or more often, not just at revalidation (42 CFR 455.436). If the state asks for fingerprints, you and every 5% owner have 30 days to provide them (42 CFR 455.434).
Your risk level can go up. A state must raise a provider to high risk when it owes an existing Medicaid overpayment, faces a payment suspension tied to a credible fraud allegation, or was excluded within the past decade. Our provider risk levels entry explains the tiers, and the Medicaid site visit guide covers the inspection.
Revalidation also repeats the ownership disclosures (42 CFR 455.104): names, addresses, birth dates, and Social Security numbers for each owner or controlling party and each managing employee, and any owners who are close relatives of one another (spouse, parent, child, or sibling). Failing to give timely, accurate information is grounds for termination (42 CFR 455.416).
The application fee
For 2026 the fee is $750, due on any institutional provider application filed between January 1 and December 31, whether a first enrollment or a revalidation. CMS guidance lists non-emergency transportation providers among the institutional entities that bill fee-for-service Medicaid and must be charged, following each state’s plan.
The fee is waived for a company already enrolled in Medicare or in another state’s Medicaid program, or one that has paid it to Medicare or to another state (42 CFR 455.460). Simple updates, such as a new phone number, bank account, or billing address, are not charged. Adding a practice location or a new owner is. CMS can grant a hardship exception when a provider documents that the fee would cause financial hardship. You send the request and proof to the state, and CMS makes the decision.
Changes to report between revalidations
Revalidation is only the scheduled check. Many changes must be reported as they happen, and missing those deadlines can end an enrollment on its own.
| Change | Federal rule | Texas | Florida |
|---|---|---|---|
| Ownership | Updated disclosures within 35 days | A new enrollment application within 30 days, with the sale contract naming who owes overpayments for earlier dates | Report it 60 or more days in advance |
| Officers, directors, managing employees | Disclose at enrollment and revalidation | Within 30 days | Within 30 days |
| Address, phone, name, tax ID | Set by the state | Within 90 days | Within 30 days |
| A new service location | Screened like a new application | Moderate- and high-risk providers may not bill from it before approval | Report within 30 days, like any enrollment change |
Texas warns that failing to report changes on time violates Medicaid rules and can bring administrative, civil, or criminal liability. Florida may terminate providers who skip required change reports. Check your state manual for vehicles and drivers too. North Dakota’s 2026 plan asks NEMT providers for proof of vehicle registration and active insurance, and for each employed driver to enroll.
What a lapse costs
A lapse is far more expensive than the paperwork.
- Payments stop. Texas disenrolls from every state health care program, including Medicaid health plans, and denies claims and prior authorizations. Florida makes a provider ineligible for payment in both fee-for-service and managed care.
- Payments in the gap are at risk. CMS guidance says payments made between a missed due date and completed screening could be flagged as improper in a PERM review.
- Getting back in means starting over. A deactivated provider must be screened again and pay any application fee (42 CFR 455.420). CMS treats reenrollment as essentially a new enrollment, so a moratorium on new transportation providers can keep a lapsed company out until it ends. Screening also jumps to high risk for a provider that was blocked by a moratorium and applies in the six months after it ends.
- Plan and broker trips end. Plans must drop network providers the state has not enrolled, including companies that work through the plan’s broker.
- Idle enrollments lapse too. In Texas, 24 months without a claim from a billing location gets it disenrolled until it reenrolls.
A revalidation checklist
Start six months before your due date.
- Confirm the due date in your state portal, and make sure the email and mailing address on file reach someone who reads them.
- Update your NPI record in NPPES so the name, address, and taxonomy match your Medicaid file. See getting an NPI for a NEMT company.
- List each owner holding 5% or more, plus each managing employee, with the details the disclosure asks for.
- Gather current documents: business licenses, vehicle registrations and insurance, and driver files.
- Run every owner, manager, and driver through the OIG exclusion list.
- Submit as soon as the window opens. Texas opens 180 days early.
- Get the office and vans ready for an inspection if your risk level requires one.
- Answer follow-up requests fast. Texas does not treat revalidation as complete until every deficiency is fixed, and in its 2026 revalidation of high-risk services, Minnesota gave providers appealing a termination seven business days to answer a request for more information.
- Confirm the approval in writing and send it to your brokers and plans.
If your state denies the revalidation, see our guide to a denied Medicaid application for appeal and reapplication steps.
Keeping driver and vehicle files current
Revalidation goes faster when registrations, insurance, and driver licenses are already current. HealthRide keeps license, insurance, and registration expiration dates for drivers and vans on its fleet page, sends reminders before they run out, and flags anything expired before a trip is assigned. Drivers also check their van in the app at the start of every shift.
Frequently asked questions
- When is my Medicaid revalidation due, and how do I check?
- Your state tells you. Texas and Arizona show the due date in their provider enrollment portals. Ohio notifies providers 90 days ahead of the agreement's expiration, and New York sends its notices by email and mail. Both of those states say not to start until the notice arrives, so make sure the state can reach you.
- Will I be charged an application fee when I revalidate?
- Often. For 2026 applications, the federal fee for institutional providers is $750, charged at revalidation as well as first enrollment. CMS lists non-emergency transportation providers among the institutional entities states must charge. Companies already in Medicare or in a second state's Medicaid program, or that paid the fee to one of them, are exempt. CMS can grant hardship exceptions.
- I only run broker and health plan trips. Do I still have to revalidate?
- Yes. Under federal rules, the state screens, enrolls, and revalidates on schedule all network providers used by Medicaid health plans, including companies that work through a plan's broker. Plans get a single 120-day window to contract with a provider whose enrollment is still pending, and they must terminate the contract right away if the state turns the provider down. New York says the same thing directly: revalidation applies to providers who only serve managed care members. CMS guidance adds that only enrolled providers may furnish NEMT.
- Do claims stop while my revalidation is under review?
- Not in Texas, where you can keep filing claims while the review runs. If you submit before the due date and the state approves within the 45-day grace period, enrollment has no gap. Once a due date passes without a completed revalidation, CMS warns that payments for that gap can be cited as improper, and states such as Texas disenroll the provider.
- Does being picked for early revalidation mean the state suspects fraud?
- No. New York says a revalidation notice, even on an accelerated timeline, does not indicate suspicion of wrongdoing, and that a high risk designation does not mean an individual provider is suspected of fraud. CMS lets states call off-cycle revalidations for many reasons, including random checks, complaints, and national initiatives.
- What does a lapsed enrollment mean for my company?
- You start over. A deactivated or terminated provider has to be screened again as if it were new, and pay any application fee. That takes time, and where a state has frozen new transportation enrollments, the new application can be turned away until the freeze lifts. North Dakota and Minnesota's seven-county metro area both had NEMT moratoriums in 2026.
Official resources
- Federal revalidation rule (42 CFR 455.414) on eCFR
- CMS Medicaid Provider Enrollment Compendium: revalidation, fees, and hardship exceptions
- New York Medicaid revalidation schedule and FAQs
- Texas Medicaid: revalidation and reporting changes (TMPPM Section 1)
- NPPES: update your NPI record
- HHS OIG: search the exclusion list for owners and staff