By Jessica Carden, PESC
Senior Director, Provider Enrollment
CMS is continuing to crack down on providers, revoking their eligibility to receive reimbursement for services rendered to Medicare beneficiaries — and we’re now seeing some of these actions extend into state Medicaid programs as well.
As reported by law firm Maynard Nexsen, on July 21, 2026, HHS held a press conference announcing federal actions to curb fraud and abuse across Medicare and Medicaid. The headline for anyone in provider enrollment: HHS delegated exclusion authority to CMS. Historically, only the HHS Office of Inspector General could exclude individuals and entities from federal health care programs; per Maynard Nexsen’s analysis, HHS Secretary Kennedy has now expanded that authority so CMS can wield the exclusion laws as well — a change HHS itself described as a “force multiplier.” In plain terms, the agency that already controls your Medicare billing privileges can now also exclude you outright, and it has signaled every intention of using that authority aggressively.
The volume tells the story. According to Maynard Nexsen, in the first quarter of 2026 CMS revoked 1,413 providers and suppliers — a 40% surge over prior years and the largest quarterly increase on record. The reasons run the familiar range: felony and misdemeanor convictions, health care fraud, patient abuse or neglect, billing for medically unnecessary or substandard services, kickback arrangements, and other compliance violations.
Revocation vs. Exclusion — and Why Both Should Worry You
These are two distinct tools, and it’s worth understanding the difference. As Maynard Nexsen’s analysis lays out:
- Revocation ends a provider’s Medicare billing privileges. It can be triggered by noncompliance with enrollment requirements, false or misleading information on an enrollment application, certain felonies, or exclusion/debarment from other federal programs.
- Exclusion is broader and more severe. An excluded individual or entity loses the right to participate in federally funded programs altogether — and cannot even furnish administrative or management services within a health care organization. An excluded person can’t serve as CEO, CFO, general counsel, or in any management role. The effects ripple through the entire organization, not just the billing line.
The Part Enrollment Teams Can’t Afford to Miss
Revocations aren’t limited to provider misconduct. As the Maynard Nexsen analysis notes, providing false or misleading information on an enrollment application — or otherwise failing to comply with enrollment requirements — is itself a basis for revocation. In practice that means providers and organizations can face serious consequences simply for failing to properly report required information to CMS through PECOS: criminal history disclosures, adverse legal actions, ownership or managing-employee changes, and other required enrollment information. Inaccurate, incomplete, or untimely enrollment reporting can place a provider’s billing privileges at risk all on its own. No fraud required — just a reporting failure.
This is exactly where provider enrollment moves from back-office function to frontline safeguard.
This Feels Like the First Wave
Given the new exclusion authority and the record revocation numbers, I expect additional enforcement activity to follow. The takeaway for healthcare organizations is clear:
- Strengthen provider screening and background verification.
- Ensure provider enrollment teams are maintaining accurate and timely PECOS reporting.
- Tighten billing compliance and documentation processes.
- Educate both administrative and service-delivery teams on CMS enrollment requirements and compliance expectations.
Revocations and exclusions can be temporary or permanent, but either can result in significant revenue loss, operational disruption, reputational damage, and downstream impacts with Medicaid and other payers.
→ Learn More About Provider EnrollmentGet your administrative and service-delivery teams up to speed — this is serious. Provider enrollment is no longer just an administrative function. It’s a critical safeguard for compliance, revenue integrity, and organizational risk management.
Source: Jenna K. Godlewski and Alice V. Harris, “CMS Granted ‘Force Multiplier’ Exclusion Power as Revocation Volumes Explode,” Maynard Nexsen PC, July 23, 2026, https://www.maynardnexsen.com/publication-cms-granted-force-multiplier-exclusion-power-as-revocation-volumes-explode. Underlying figures and announcement from the HHS press conference of July 21, 2026. Regulatory facts and statistics in this article are drawn from that publication; commentary and recommendations are the author’s own.
