On April 23, 2026, Centers for Medicare & Medicaid Services (CMS) Administrator Dr. Mehmet Oz issued directives to all 50 governors and State Medicaid Directors requiring states to significantly strengthen Medicaid provider enrollment oversight through accelerated revalidation efforts.

Florida has not yet released its response or proposed strategy — but the direction from CMS is clear, and the implications for home care providers are substantial.

What CMS is Requiring

CMS is mandating two immediate actions from states:

1. Within 10 days (May 7): States must submit a timeline for the swift revalidation of “high-risk” providers.
2. Within 30 days: States must submit a comprehensive two-year provider revalidation strategy, with an emphasis on off-cycle revalidations targeting high-risk providers.

CMS is positioning these requirements as essential to ensuring that only qualified providers participate in Medicaid and that provider enrollment data remains accurate and up to date. In parallel correspondence, the agency made clear that a state’s responsiveness will factor into federal assessments of fraud risk.

A Broad Directive — But Clear Signals for Home Care

The directive does not specifically target home health agencies or any single provider type. Instead, it applies broadly to providers considered at high risk for fraud, waste, or abuse.

However, early industry interpretation — and CMS’s recent enforcement posture—indicate that home- and community-based services (HCBS) will be a central focus.

As Damon Terzaghi of the National Alliance for Care at Home noted, personal care and related home care services are likely to be “front and center” in this initiative. More broadly, he emphasized that many states have fallen behind on routine revalidations due to administrative strain, creating vulnerabilities that CMS is now moving aggressively to address.

This aligns with CMS’s recent enforcement activity in multiple states and its broader emphasis on program integrity in Medicaid-funded home care services.

Why This is Happening Now

CMS is responding to what it describes as a growing and increasingly sophisticated fraud environment within Medicaid. At the same time, states have struggled to keep pace with required revalidation cycles — often exceeding the standard three- to five-year timeframe.

That combination — rising program integrity concerns and delayed oversight — has prompted CMS to push for faster, more frequent, and more targeted revalidation efforts.

Expansion of “High-Risk” Oversight

While CMS does not redefine “high-risk” providers in these letters, it is clearly encouraging states to expand how the designation is applied.

Key signals include:

• Increased reliance on off-cycle revalidation
• More frequent screening for high-risk categories
• Explicit expectation that providers without National Provider Identifiers (NPIs) be treated as high risk  

This last point is particularly relevant to the broader home care ecosystem, where certain HCBS providers — especially non-medical services — may not have NPIs and could face increased scrutiny as a result.

What This Means for Providers

Even without being explicitly targeted, home health agencies should expect to be affected.

States retain discretion in defining high-risk categories, and CMS is clearly encouraging a more aggressive approach. As a result, providers may see:

• Off-cycle revalidation requests outside the normal schedule
• Shorter response timelines
• Increased scrutiny of enrollment records, ownership disclosures, and compliance history

For providers that rely heavily on Medicaid reimbursement, these processes carry meaningful operational and financial risk.

What Providers Should Do Now

Audit Your Enrollment File

Ensure all information is current, including:

• Ownership and managing employees
• Practice locations and contact information
• Licensure and certifications

Strengthen Internal Monitoring

• Track all Agency for Health Care Administration (AHCA) and managed care communications
• Assign clear responsibility for enrollment oversight

Prepare for Accelerated Timelines

• Expect shorter response windows
• Treat revalidation like a high-stakes regulatory filing

Be Ready to Respond to Denials

Denials often result from administrative or documentation issues. Providers should be prepared to respond quickly and pursue available appeals when appropriate.

Bottom Line

CMS’s directive is not narrowly targeted — but it signals a clear shift toward more aggressive oversight across the Medicaid program, with a particular emphasis on home care and HCBS.

Ensuring Medicaid enrollment is accurate, current, and defensible is no longer just best practice — it is essential to maintaining participation and avoiding disruption.

Related:

• CMS Asks States to Submit Medicaid Provider Revalidation Strategies, Increase Oversight (McKnight's Home Care, 4/23/26)
• Dr. Oz Puts All 50 Governors on Notice Over Billions Lost to Medicaid Fraud (Fox News, 4/23/26)
• Governors and State Medicaid Directors Get a New Assignment from Dr. Oz: Quickly Recertify “High-Risk” Providers (Georgetown University Center for Children and Families, 4/24/26)