Revocation does not just stop billing. It sets a bar on coming back, and the routes to challenge it run on separate clocks.
Request a Free Case ReviewCMS may revoke Medicare billing privileges under 42 C.F.R. § 424.535 on a range of grounds, from non-compliance with enrollment requirements to felony convictions, abuse of billing privileges, and failure to report reportable events. Revocation ends the ability to bill Medicare and typically comes with a re-enrollment bar.
Two routes exist and they are not alternatives to be chosen at leisure. A corrective action plan is available for some grounds and not others, and it runs on a short deadline. Reconsideration preserves the appeal and leads to an ALJ of the HHS Departmental Appeals Board. Choosing the wrong one, or missing the shorter of the two, is how recoverable revocations become permanent.
.png)
Anthony's background as a former federal prosecutor and executive for major healthcare companies provided a level of expertise and insight that made all the difference. His deep understanding of healthcare law, particularly in litigation and compliance matters, helped navigate complex legal issues with ease.
With upmost professional respect, I will be forever grateful to have such caring individuals as Attorney Anthony Mahajan and Attorney Diana Yastrovskaya who come into my life, even though I am a business owner but I always felt I was treated as a friend and was made reaching out to them with ease.
I had a great experience working with Health Law Alliance. From the very beginning, their team was incredibly helpful, responsive, and professional. They answered all of my questions quickly and kept me informed throughout the entire process.
Anthony and his staff have gone above and beyond. His proactive communication and ability to handle complex legal scenarios effectively have been a significant asset. Highly recommended attorney.
Top-notch attorneys with an unparalleled scope of experience and breadth of knowledge. You will want them in your corner.
Had nothing but great experience from them. Knowledgeable and professional in all aspects. They have a vast knowledge in health care cases, great to be on your side against insurances.
Trustworthy and experienced.
The immediate effect is the loss of Medicare billing privileges, often with a retroactive effective date that turns already-submitted claims into overpayments. The re-enrollment bar then determines how long the provider is out. Beyond Medicare, revocation is a reportable event for many state programs, commercial payors and licensing boards, and it can lead to placement on the preclusion list affecting Medicare Advantage and Part D.
Depending on the ground, the revocation may take effect before the date of the notice. Claims already paid in that window become overpayments, so a revocation can generate a recoupment demand as well as ending future billing.
A re-enrollment bar of several years is, for most Medicare-dependent providers, indistinguishable from closure. The length is set by CMS and depends on the ground and the history, which makes challenging the characterisation of the conduct as important as challenging the facts.
Revocation is commonly reportable to state Medicaid programs, commercial payors, and licensing boards, and can support placement on the preclusion list for Medicare Advantage and Part D. One determination can therefore close several revenue lines at once.
Four features shape how a revocation has to be answered.
The first response is not a routine administrative task. It establishes the documents, timing, and record the contractor can later use in its findings and on appeal.
Four stages, with the route decision made in the first days.
We identify precisely which subsection of § 424.535 CMS relied on, what the effective date is, what bar has been set, and both deadlines. That determines whether corrective action is even available and what has to be filed first.
Where the ground is curable non-compliance, the underlying problem gets fixed and documented straight away, because a corrective action plan describing a completed fix is a different document from one promising a future one.
The reconsideration submission is prepared as the evidentiary record: enrollment file, correspondence, the operational facts, and where the characterisation of conduct is wrong, the material that shows it. It is written knowing an ALJ will read it.
We take the matter to the ALJ and, where necessary, to the Board’s appellate division. In parallel we deal with the consequences: overpayment exposure from any retroactive date, payor and board reporting, and the practical route to re-enrolment when the bar expires.
Health Law Alliance handles the response and any parallel appeal, licensing matter or referral as one coordinated matter, so the strategy does not change hands as the matter moves between forums.
The bench includes a former Assistant U.S. Attorney nominated for the DOJ Director's Award, senior healthcare-company counsel, and attorney-providers with experience across healthcare audits and investigations.
Agency and company marks identify former professional experience of individual HLA team members. They do not imply affiliation, endorsement, or a client relationship.
Seven questions that come up on almost every first call. The answers below are general; specific situations require privileged consultation.
Send us the revocation notice. We will tell you which ground CMS relied on, whether corrective action is available, what both deadlines are, and what the reconsideration submission needs to contain. Free, confidential, no retainer.