As a requirement of the Patient Protection and Affordable Care Act ("PPACA"), all Texas Medicaid providers, including ordering and referring providers¹, must revalidate their enrollment in the Texas Medicaid program if they initially enrolled before January 1, 2013. This applies to providers who participate in Medicaid managed care, traditional fee-for-service Medicaid (each active TPI Suffix), the Texas Vendor Drug Program², and in long-term care services administered through the Texas Department of Aging and Disability Services (DADS)³. Providers can re-enroll through the Texas Medicaid and Healthcare Partnership (TMHP)⁴ or through the Texas Health and Human Services Commission.⁵

The Centers for Medicare and Medicaid Services ("CMS") extended the original March 24, 2016 re-enrollment deadline to September 24, 2016. The consequence for failure to comply with this deadline is disenrollment, making the provider ineligible for reimbursement.

To avoid payment disruptions, Texas Medicaid requests all providers submit their re-enrollment applications on or before June 17, 2016. These providers will remain in Texas Medicaid even if the re-enrollment process is not complete by September 24, 2016 so long as the provider timely addresses deficiencies. Texas Medicaid, however, will not extend this courtesy to providers that submit applications after June 17, 2016. Instead, those providers will be disenrolled from Texas Medicaid, and suffer a gap in enrollment (and thus reimbursements) from September 25, 2016 to the date the application is finally approved. Even upon approval, a provider will not qualify for retroactive reimbursements.

Significantly, re-enrollment requires disclosure of whether the "legal entity [has] ever been sanctioned in any federal or state program." indluding state administrative penalties. TMHP and DADS require disclosure of all sanctions incurred by the legal entity under the current ownership. This is in stark contrast to the current requirements that limit a provider's obligation to keep records five (5) years. See, e.g., 15 TEX. ADMIN. CODE § 371.1719. Even though many providers will not have complete records to support the mandated disclosures, all providers should include information as far back as possible and then submit an explanatory statement for any deficient records.

¹ Providers who solely order or refer services for Medicaid clients must now enroll with Texas Medicaid as participating providers. Click here.

² Vendor Drug Program providers can visit here for additional guidance.

³ DADS regulated providers can visit here for additional guidance. Long-term Services and Support (LTSS) providers without an active DADS Medicaid contract or TPI to bill TMHP must re-enroll through the Medicaid MCO LTSS provider re-enrollment process. For more information and next steps, email Texas.Medicaid.Enrollment@dads.state.tx.us.

⁴ Click here.

⁵ Click here.