(a)(16) Misdemeanor conviction
- Sexual assault or financial misconduct, 10 years
- Final adverse action [1]
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Insight · Medicare provider enrollment
CY 2027 provider enrollment proposals: what CMS wants to change, section by section
Short answer: section V.C of CMS-1844-P reaches every Medicare provider and supplier type: all revocations retroactive, wider denial grounds, a 10-year bar after any denial, a tighter 36-month ownership rule. Proposed, not final.
CMS-1844-P · 91 FR 41216
42 CFR 424.535(g) · effective dates
42 CFR 424.530(f) · reapplication bar
Comments closed Aug 31, 2026
Edition
Insight · Oct 2026
Focus
Provider enrollment
Audience
Credentialing · Compliance
Framework
CMS-1844-P · 91 FR 41216
Horizon
CY 2027 · proposed
Length
6 min read
Five dates, nothing in force yet
Section V.C applies to all provider and supplier types except as indicated [1].
- 1Dec 2, 2025CY 2026 final rule: many grounds already retroactive (90 FR 55342)
- 2Jul 1, 2026CMS fact sheet released [2]
- 3Jul 6, 2026Proposed rule published, 91 FR 41216 [1]
- 4Aug 31, 2026Comment period closed
- 5PendingFinal rule; nothing here is in force
In force today
424.535(g)(2) retroactive list
Proposed
All grounds retroactive, new denials
Your window
Audit reporting now
In forceProposedYour move
Nine rules, before and after
| Rule | Today | Proposed in CMS-1844-P |
|---|---|---|
| Revocation effective date, 424.535(g) [1] | 30 days after notice unless on the (g)(2) list | Every remaining ground retroactive |
| Reapplication bar, 424.530(f) [1] | Up to 10 years, false-information denials only | Up to 10 years after any denial; weighing factors deleted |
| Pattern of non-compliant claims, (a)(8)(ii) [1] | Four factors weighed first | Factors removed |
| False or misleading information, (a)(4) [1] | The application only | Any enrollment-related document; one denial can revoke other enrollments, 424.535(i) |
| Reactivation effective date, 424.540 [1] [4] | Receipt date, no rebuttal | 15-day rebuttal via 424.546 |
| Hospice reactivation, 424.540(b)(3)(i) | No survey | Survey or accreditation first |
| Definition of operational | Open and staffed | Briefly open or unqualified staff no longer passes |
| PE and REIT disclosure | SNFs only | Other CMS-855A filers; signage, moratoria, opt-out also revised [1] |
| Majority ownership, 424.550(b) and 424.551 | HHA, hospice, DMEPOS re-enroll after a change inside 36 months | New denial (a)(22) and revocation (a)(25); CMS names unreported sales and management agreements |
Proposed retroactive effective dates by revocation reason
| Revocation reason, 424.535(a), selected [1] | Proposed effective date |
|---|---|
| (a)(1) Non-compliance | Date the non-compliance began |
| (a)(4) False or misleading information | Date the false information was submitted |
| (a)(5)(ii) Enrollment requirement not met | Date the requirement was not satisfied |
| (a)(9) Late enrollment change report | Day after the report was due, every type of change |
| (a)(10) Documentation not retained or furnished | Date of the retention failure; day after access was due |
| (a)(13) DEA certificate lost | Date of the revocation, suspension or surrender |
| (a)(14), (a)(21) Improper prescribing, ordering, certifying, referring | Date of the last prescription or order in the pattern |
| (a)(15) False Claims Act judgment | Date of the judgment |
| (a)(17) Debt referred to Treasury | Date CMS referred the debt |
| (a)(18) Prior revocation under another identity | Effective date of the current enrollment |
| (a)(20) Billing from a non-compliant location | Earliest date of service on the triggering claims |
What section V.C adds, counted
Section V.C provisions by type
24 items from the rule text [1].
Revocation reasons made retroactive424.535(g), selected
1146% of 24 items
New denial grounds424.530(a)(16) to (a)(22)
521%
Other provisionstable above
521%
Factor tests removed(a)(8)(ii), 424.530(f)
28%
Reapplication bar widenedany denial reason
14%
036911 items
Revocation sideDenial sideOther provisions
Five new denial grounds in 42 CFR 424.530(a)
(a)(19) Shared suite
- Same suite as a revoked or denied provider
(a)(20) Hospice director
- Serving multiple hospices, too distant, or unlicensed
(a)(21) Borrowed identity
- Attempting to enroll under another party’s identity
(a)(22) Ownership rules
- HHA, hospice or DMEPOS that broke the 36-month majority-ownership rules
Takeaway
The date you missed becomes the date your billing privileges ended. The defense is a reporting record you can prove.
Four checks before the final rule
Audit 12 months of enrollment changes30- and 90-day deadlines, 424.516; file anything late [3].
Monitor owners and managing employeesTheir suspensions would tie to yours [2].
Check every practice location on fileOperational definition and shared suites, before the next CMS-855.
Date the last majority-ownership changeHHA, hospice, DMEPOS: 36 months is a hard boundary.
Next: the 2027 operating model, avoiding a stay, the November Brief. Our credentialing team runs the check in CredPro; see the vendor evaluation guide and CMS's MAC timeliness calculators [5].
Frequently asked questions
Where are the CY 2027 enrollment proposals published?
In the CY 2027 Home Health Prospective Payment System proposed rule, CMS-1844-P, published in the Federal Register on July 6, 2026 at 91 FR 41216, section V.C Provider Enrollment. Comments closed August 31, 2026. A final rule had not been published when this page was checked.
Do the proposals apply to physician groups and behavioral health providers?
Yes. CMS states the section V.C provisions apply to all Medicare provider and supplier types except where a provision says otherwise. Only the hospice medical director and administrator ground, the change-in-majority-ownership ground and the hospice reactivation survey rule are limited to specific types.
What is the proposed change to the reapplication bar?
Today CMS may bar a denied applicant from reapplying for up to 10 years only when the denial was for false or misleading information. CMS proposes to allow a reapplication bar of up to 10 years after any denial reason in 42 CFR 424.530(a), at its discretion.
What is the 36-month rule?
Under 42 CFR 424.550(b) and 424.551, an HHA, hospice or DMEPOS supplier that undergoes a change in majority ownership within 36 months of initial enrollment or its last such change must enroll as a new provider and undergo a survey or accreditation. CMS proposes new denial and revocation grounds for failing to comply, including sales dressed up as management agreements.
- Federal Register, 91 FR 41216 (July 6, 2026): CY 2027 Home Health PPS proposed rule, CMS-1844-P, section V.C Provider Enrollment (proposed, comments closed August 31, 2026)
- CMS fact sheet: Calendar Year (CY) 2027 Home Health Prospective Payment System Proposed Rule (CMS-1844-P), July 1, 2026
- 42 CFR 424.516, Additional provider and supplier requirements for enrolling and maintaining active enrollment status (reporting deadlines)
- 42 CFR 424.540, Deactivation of Medicare billing privileges
- CMS, Medicare Provider Enrollment Compliance Conference, March 18 to 19, 2026: provider resources (revalidation list, stay of enrollment education, EUS)
Checked October 25, 2026. Rules change; confirm against the source before relying on them. CMS-1844-P is a proposed rule and nothing in it is final until CMS publishes the final rule.
Want the proposal mapped onto your own roster?
We check your reporting history, locations and owner monitoring against each provision before the final rule.