DHS Publishes Bulletin on Off-Cycle Revalidation of High-Risk Providers
Author
Fady Sahhar
Date
October 5, 2026
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The Office of Long-Term Living (OLTL) presentation during the RCPA conference emphasized the importance of the revalidation process, stating that it applies to the majority of services when time and attendance are used, including residential habilitation.
The Pennsylvania Department of Human Services (DHS) is requiring certain Medicaid providers classified as high risk to revalidate their enrollment by December 31, 2026, even if their normal five-year revalidation date has not arrived. The bulletin covers all high-risk providers who last revalidated before July 1, 2025, plus selected high-risk providers who revalidated on or after that date. DHS says this accelerated review responds to a CMS request concerning provider screening and program integrity.
A provider may be classified as high risk under the bulletin because of a fraud-related payment suspension, a qualifying federal exclusion, a specified unresolved overpayment above $1,500, or enrollment soon after a federal moratorium ends.
What providers need to do: Check the enrolled email address and the revalidation date for each service location in PROMISe. DHS will send individual communications and 90-day and 30-day notices to affected providers; the date in a provider’s notice controls its submission. A high-risk service location that misses its stated deadline will be closed in PROMISe. DHS advises submitting revalidation applications at least 60 days before the applicable date. After this special revalidation, the bulletin sets the next date in December 2028, followed by a return to a five-year cycle.Top of Form
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View the bulletin for complete details. If you have any questions, contact Fady Sahhar.



