Losing the ability to bill Medicare or Medicaid can be devastating for any healthcare professional or facility. Whether you're a solo practitioner, part of a group, or running a healthcare business, a revocation of your enrollment doesn’t just impact your revenue—it puts your entire career and reputation on the line.
If you’ve received notice of revocation or are under investigation by CMS or the OIG, don’t panic—but don’t ignore it either. These situations can escalate quickly, and your window to respond is short. Here's what you need to know and how to start fighting back.
Why Medicare or Medicaid Enrollment Can Be Revoked
Contrary to popular belief, you don’t have to commit fraud to get your Medicare or Medicaid billing privileges revoked. In fact, some revocations stem from issues as simple as outdated information, paperwork errors, or staff mistakes.
Common reasons for revocation include:
- Submitting claims for services not provided
- Using incorrect billing or CPT codes (especially when it increases payment)
- Employing or contracting with excluded individuals
- Failing to report address changes or practice closures
- Violating the terms of your provider agreement
- Being linked to a prior sanction, disciplinary action, or conviction
- Not responding to a Medicare revalidation request
CMS and the OIG take these matters seriously—and even unintentional mistakes can be treated as “abuse” of the system
What Happens After a Revocation Notice
If you receive a Medicare revocation letter (CMS Form 855R or similar), it means CMS believes there is cause to terminate your billing privileges. This is often accompanied by a re-enrollment bar—typically lasting between 1 and 3 years.
Once you receive the notice, the clock starts ticking. You generally have 30 days to submit a request for reconsideration, which is the first step in the appeals process.
Appealing a Medicare or Medicaid Revocation
You do have rights—but the appeals process can be complex and technical. Here’s how it typically unfolds:
- Request for Reconsideration
This is your chance to challenge the revocation. You must submit supporting evidence (not just arguments) showing why the revocation is wrong or how you've corrected the issue. - Corrective Action Plan (CAP)
If the revocation is based on a deficiency (rather than fraud), you may be allowed to submit a CAP. This outlines the steps you’ve taken to fix the problem—like staff training, software upgrades, or policy changes. - Administrative Law Judge (ALJ) Hearing
If CMS denies your reconsideration, you can appeal to an ALJ. This is a formal hearing where evidence, witnesses, and legal arguments can be presented. - Departmental Appeals Board (DAB) Review
If the ALJ also rules against you, you may appeal to the DAB. This is usually the final administrative step before pursuing action in federal court.
Don’t Wait—Talk to a Healthcare Defense Attorney Early
Here’s the truth: once a revocation happens, the burden shifts to you to prove why it was wrong—or why you deserve reinstatement. And CMS doesn’t make that easy.
At The Callahan Law Firm, we help healthcare providers nationwide fight Medicare and Medicaid revocations, respond to OIG audits, and appeal enrollment denials. We know how high the stakes are, and we’re here to help you build the strongest case possible.
Whether you’re facing a potential revocation or already received a notice, we can step in quickly and help protect your license, your livelihood, and your reputation.
