Providing healthcare services to Medicaid beneficiaries in New York requires New York State Medicaid provider enrollment. Per a recent announcement, New York State implemented a temporary Medicaid enrollment moratorium for the following types of providers: pharmacies, laboratories, durable medical equipment, prosthetics, orthotics, and supplies providers, applied behavior analysis providers, licensed home care services agencies and certain managed long-term care plans.
According to the New York State Department of Health, “During the moratorium period, all pending applications, regardless of stage of review, will be discontinued effective immediately. This includes applications at any point in the review process, whether in initial submission, under active review, or awaiting final determination. No applications will be processed or advanced during the moratorium period. Applicants may (re)initiate an application following the conclusion of the moratorium.”
The New York State Department of Health has indicated that the existing enrolled providers in these affected types of providers are not impacted. Thus, the existing providers should continue to monitor for revalidation notices and respond promptly when notified.
This moratorium, however, may have an immediate impact on providers with pending provider enrollment applications and providers subject to pending or anticipated healthcare transactions. For example, depending on the transaction structure, if a change in ownership or control requires Medicaid enrollment approval or updates, delays in obtaining such approval could affect transaction timelines and require consideration of alternative options and mitigation strategies. Providers and transaction parties should monitor these developments and any additional regulatory guidance regarding the moratorium closely as they evaluate the impact on the pending or planned transactions.
