New York State Department of Health Imposes Six-Month Medicaid Provider Enrollment Moratorium

On July 30, 2026, during the State of the State of New York Medicaid presentation at the United Hospital Fund’s 2026 Medicaid Conference, Medicaid Director Amir Bassiri announced an immediate, six-month moratorium on new Medicaid provider enrollments, including processing affected changes of ownership (CHOW) applications, for certain provider categories. The moratorium comes in response to a directive from the Centers for Medicare & Medicaid Services (CMS), issued to all state governors on April 23, 2026, requiring all states to revalidate every enrolled Medicaid provider within 24 months.¹

While provider revalidation has always been required under federal law, the CMS letter directed states to undertake an “expedited” revalidation process—a requirement that was largely suspended during the COVID-19 Public Health Emergency (PHE) and was slow to return after the PHE ended in 2023. Unlike several ongoing federal Medicare moratoria,² New York’s Medicaid moratorium is expected to be temporary, designed to give the state time to update its fully automated, rather than paper-based, provider enrollment platform—called the Provider Services Portal—and complete the federally mandated revalidation of existing Medicaid enrollments without the additional burden of processing new paper enrollments and CHOWs. The Provider Enrollment Portal is expected to launch in Fall 2026.

The moratorium on enrollment applies only to the following provider categories deemed “high risk” by CMS:

1. Laboratory;
2. Durable Medical Equipment (DMEPOS);
3. Applied Behavior Analysis (ABA);
4. Licensed Home Care Services Agencies (LHCSAs);
5. Pharmacy; and
6. Managed Long Term Care Plans (i.e., MLTC Partial Cap, MAP, and PACE).

The moratorium will immediately affect providers with pending enrollment applications or planned changes of ownership—applications will be delayed or denied during the moratorium period; indeed, DOH stated it will not process applications during the moratorium, regardless of the stage of the application.

While additional details may be forthcoming on the contours and impacts of the moratorium, certain types of pending and future transactions involving the affected provider types will likely be impacted. Specifically, equity transactions often require an update to the acquired provider’s enrollment with Medicaid, and thus likely will be halted by the moratorium. However, transaction structures that do not require a new Medicaid enrollment or an update to existing enrollment information may not be impacted. Moreover, it is unclear whether the New York State Department of Health (DOH) will halt other aspects surrounding approval of CHOWs, such as the already lengthy “Schedule 1” process impacted by LHCSA CHOWs.

Parties considering transactions involving the affected provider categories should carefully evaluate how the moratorium may affect transaction timing, structure, and closing conditions.

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Ropes & Gray will continue to monitor developments in this area, especially as DOH is expected to provide additional information in the coming days. If you are interested in discussing the moratorium, please reach out to one of the authors or your usual Ropes & Gray advisor.