The first two are CMS telling you. The last three are CMS stopping you. Lanes show who acts at each station.
A stay is survivable if you file inside it: when compliance is restored before the stay ends, claims from inside it become payable and may be resubmitted [3]. A deactivation is not reversible for the days in between, because the reactivation date is the day your paperwork arrived [4].
CMS source for the 7, 3 to 4 and 3 month figures [1]; 60-day stay from 42 CFR 424.541 [3].
| State | Still enrolled? | Claims with a date of service in the gap | Way back |
|---|---|---|---|
| Hold on reimbursement [1] | Yes | Payment held until the revalidation completes | Complete the revalidation |
| Stay of enrollment, 42 CFR 424.541 [3] | Yes | Rejected; payable only if compliance resumes before the stay ends | File the fix inside the 60 days; rebut within 15 days if the stay is wrong |
| Deactivation, 42 CFR 424.540 [4] | Privileges deactivated | Not payable, 424.540(e); never recoverable | Reactivation, effective on the receipt date of the approved submission |
| Retrospective billing, 42 CFR 424.521 [5] | New enrollees only | Does not cover a revalidation gap; written for a new effective date (30 days back, 90 in a declared disaster) | Not a way back |
CMS says you are responsible for tracking your own due date [1]. So the calendar is yours, not the notice's.
| Event | Deadline | If missed |
|---|---|---|
| Leaving Medicare: retirement, licence surrender, end of participation [7] | 90 days 30 days DMEPOS | CMS warns of fraudulent billing exposure or revocation |
| Opt-out status [7] | Renews every 2 years cancellation to the MAC at least 30 days before expiry | Another two-year opt-out period begins |
The due date is yours to track. Inside the stay you can still file your way out; after deactivation, every day until the paperwork arrives is unpaid for good.
For the whole model, including the CY 2027 proposal that would make a missed reporting deadline a retroactive revocation, read the credentialing revalidation operating model. The November Credentialing Brief has the 30-minute version; CMS's March 2026 enrollment compliance conference deck lists the MAC self-service tools the calendar depends on [8].
CMS posts due dates about seven months in advance on the Medicare Revalidation List at data.cms.gov. Your enrollment contractor also sends a notice by email or mail about three to four months before the date, but CMS says you are responsible for tracking the date yourself.
Only inside the window. CMS says to revalidate if you are within three months of your due date even without a notice, and not to revalidate if the date is more than seven months away unless you received a notice. Unsolicited revalidations are returned.
Under 42 CFR 424.541, CMS may stay an enrollment for up to 60 days when a provider is non-compliant with an enrollment requirement that a change-of-information or revalidation application could fix. The provider stays enrolled, but claims with dates of service inside the stay are rejected unless compliance resumes before the stay ends. You have 15 calendar days to rebut.
No. Under 42 CFR 424.540 a provider may not receive payment for services furnished while deactivated, and the reactivation effective date is the date the contractor received the submission it approved. The 30-day retrospective billing rule in 424.521 is written for new effective dates, not for a missed revalidation.
Checked October 25, 2026. Rules change; confirm against the source before relying on them.
We pull the Medicare Revalidation List for your whole roster, flag every date inside the window and show you the billing that depends on each one.