NYSCLA Alert to Laboratories (July 2026)

Crushing and Flexing: CMS Proposes to Expand Its Discretion to Deny and Revoke Medicare Enrollment

Tuesday, July 21, 2026 (Last updated: Aug 6 2026 21:45)

The Centers for Medicare & Medicaid Services (CMS) issued a proposed rule (Proposed Rule) on July 6 that would expand its authority over Medicare enrollment denials and revocations applicable to all providers and suppliers (Providers). CMS’s proposed expansion of Medicare enrollment denial and revocation authorities is consistent with the Trump administration's broader strategy of preventing improper payments before they occur.

Currently, CMS’s revocation authority allows it to revoke enrollment prospectively following notice to the Provider. Following revocation, the Provider is no longer allowed to bill Medicare. CMS’s proposal would not only make the revocation date retroactive to the date of alleged noncompliance (or other triggering event) but would also allow CMS to claw back payments to the retroactive revocation date. CMS estimates approximately $82 million in annual savings from this proposal, clearly indicating that CMS views it as a high-impact program integrity measure. 

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