Last updated: November 2026
A Medicare deactivation stops a provider's payment until it reactivates its billing privileges, and a revocation ends its enrollment and usually bars it from Medicare for 1 to 10 years, with longer bars possible for circumvention or a second revocation and no bar for some failures to respond to a revalidation or information request. Both come from 42 CFR Part 424. Integral Healthcare Solutions (IHS), a consulting firm, drafts the rebuttal or corrective action plan and the reinstatement packet; you sign and file them.
This is compliance services work, one of three IHS practice lines alongside accreditation consulting and program development. It is not legal advice, and IHS is not a law firm. We checked every section cited here against the official eCFR text (GPO, built November 4, 2026; Title 42 last amended October 8, 2026) and against the CMS Medicare Program Integrity Manual, chapter 10, section 10.6.18 (Rev. 13355), on November 5, 2026.
What are Medicare deactivation and revocation?
Deactivation stops payment until billing privileges are reactivated; revocation ends enrollment. Deactivation does not affect a provider's participation agreement or any conditions of participation (42 CFR 424.540, paragraph (c)). Revocation is governed by 42 CFR 424.535, appeal rights by 42 CFR 424.545, and reinstatement after a corrective action plan by 42 CFR 405.809.
Deactivation
Grounds in 42 CFR 424.540, paragraph (a), include submitting no Medicare claims "for 6 consecutive calendar months," failing to report a change to its enrollment application information within the required time period, failing to furnish complete and accurate information and all supporting documentation within 90 calendar days of receipt of a CMS notice to submit or recertify enrollment information, and a practice location that is non-operational or otherwise invalid. "A provider or supplier may not receive payment for services or items furnished while deactivated under this section" (paragraph (e)).
Revocation
The reenrollment bar "Begins 30 days after CMS or its contractor mails notice of the revocation and lasts a minimum of 1 year, but not greater than 10 years (except for the situations described in paragraphs (c)(2) and (3) of this section), depending on the severity of the basis for revocation" (42 CFR 424.535, paragraph (c)(1)(i)). CMS may add up to 3 more years, even past 10, if it determines a provider is attempting to circumvent the bar by enrolling under a different name, numerical identifier or business identity (paragraph (c)(2)), and may impose up to 20 years on a second revocation (paragraph (c)(3)). Under paragraph (c)(1)(ii), no bar applies to an (a)(1) revocation for failing to respond on time to a revalidation request or other request for information.
Except in the cases listed in paragraphs (a)(8)(iii), (g)(2) and (g)(3), a revocation "becomes effective 30 days after CMS or the CMS contractor mails notice of its determination" (paragraph (g)(1)). Paragraph (g)(2) sets other dates, often earlier, for listed grounds, such as the date a practice location stopped operating, per CMS or its contractor, or the day after a missed deadline to report a change of ownership, an adverse legal action, or a practice location change, addition or deletion.
Who needs it and what triggers it
A provider or supplier needs this work when one of these arrives:
- A deactivation letter (42 CFR 424.546 rebuttal window).
- A revocation for noncompliance under 42 CFR 424.535, paragraph (a)(1), the one ground that allows a corrective action plan.
- A revocation on another ground (reconsideration under 42 CFR 498.22).
- A CMS request for additional documentation, which "must be submitted within 60 calendar days of request" (42 CFR 424.535, paragraph (a)(1)(ii)).
How IHS helps
IHS builds the written file that answers the enrollment action. Dr. Thomas G. Goddard leads the work in five steps:
- Read the notice against the section it cites and build a dated timeline of every window on this page; counsel confirms each date.
- Build the root-cause file: where the enrollment record and the facts diverged.
- Draft the deactivation rebuttal, or for an (a)(1) revocation the corrective action plan, with verifiable evidence of compliance for every deficiency the notice names.
- Assemble the reinstatement packet and exhibits, indexed to the plan.
- Write a compliance calendar for change reporting and claims activity.
What you supply. The notice, enrollment and claims records, evidence of the fix (licenses, leases, insurance certificates), the signatures, and counsel for reconsideration and appeals.
The real limit. A provider "has only one opportunity to correct all deficiencies that served as the basis of its revocation through a corrective action plan" (42 CFR 405.809, paragraph (a)(2)), so completeness matters more than speed.
What to have ready
- The notice, with its date and the effective date it states (42 CFR 424.535, paragraph (g)).
- The ground cited. A corrective action plan is open only for an (a)(1) noncompliance revocation (42 CFR 405.809, paragraph (a)(1)).
- Any CMS request for additional documentation, with its date.
- Your current enrollment record and every change you reported.
- Claims history by month, to test the 6-consecutive-month ground (42 CFR 424.540, paragraph (a)(1)).
- Evidence that the deficiency is corrected, since a plan must contain "verifiable evidence" of compliance (CMS Medicare Program Integrity Manual, chapter 10, section 10.6.18(B)(2)).
- Every other Medicare enrollment you hold, since CMS may revoke those too (42 CFR 424.535, paragraph (i)).
- The name of who will sign (the individual practitioner, an authorized or delegated official, or an appointed representative), and of your counsel.
The free introductory call is the next step for turning that list into a working file.
How it compares
The three responses run on different clocks.
| Question | Deactivation rebuttal | Corrective action plan | Reconsideration |
|---|---|---|---|
| Which action | Deactivation (42 CFR 424.546) | Revocation under 424.535(a)(1) only (42 CFR 405.809) | Revocation on any ground (42 CFR 498.22) |
| Deadline | 15 calendar days from the date of the written notice; CMS may extend | Received within 35 calendar days from the date of the initial determination (CMS manual) | 60 days from receipt, receipt presumed 5 days after the notice date unless shown otherwise; extended if you show good cause |
| Limits | Decision is not appealable | One opportunity to correct all deficiencies; a refusal is not an initial determination under part 498 | Appeal continues under part 498 (42 CFR 424.545) |
| Payment while pending | None while deactivated | If reinstated, the effective date is based on the date of compliance, and CMS may pay from the effective date | "Payment is not made during the appeals process" |
The CMS manual says the reconsideration clock keeps running while a corrective action plan is under review (CMS Medicare Program Integrity Manual, chapter 10, section 10.6.18(B)(6)). Whether to file one or both is a question for counsel.
What it costs
None of the sections we opened sets a fee for a deactivation rebuttal, a corrective action plan or a reconsideration request. If a new enrollment application is needed, confirm any application fee with your Medicare contractor.
IHS scopes each engagement after a free introductory call; scope moves with the enrollments, locations and deficiencies involved. Your own staff spend time on records and draft review. Lost billing days add to the cost, since no payment is made while deactivated or during a revocation appeal.
What this is not
- It is not legal advice; reconsideration, appeals and legal strategy belong to your counsel.
- It is not a promise of reinstatement or a shorter bar.
- IHS does not file with, call or correspond with CMS or a Medicare contractor. You file what IHS drafts.
Frequently asked questions
What is the difference between deactivation and revocation of Medicare enrollment?
Deactivation stops payment until you reactivate your billing privileges; revocation ends enrollment and usually starts a reenrollment bar. While deactivated, a provider "may not receive payment for services or items furnished while deactivated" (42 CFR 424.540, paragraph (e)). After a revocation the provider is barred "from the effective date of the revocation until the end of the reenrollment bar" (42 CFR 424.535, paragraph (c)(1)).
How do we reactivate Medicare billing privileges after deactivation?
You must recertify that the enrollment information on file is correct, furnish any missing information as appropriate, and be in compliance with all applicable enrollment requirements (42 CFR 424.540, paragraph (b)(1)). CMS may also, for any reason, require a complete Form CMS-855 application as a prerequisite (paragraph (b)(2)), and a deactivated home health agency needs an initial State survey or accreditation by an approved accreditation organization before reactivation (paragraph (b)(3)(i)).
Can we dispute a Medicare deactivation?
Yes, by a written rebuttal submitted within 15 calendar days from the date of the written notice, a period CMS may extend at its discretion (42 CFR 424.546, paragraph (a)). A rebuttal that is late or misses any requirement in paragraph (b) waives your rebuttal rights, and the rebuttal decision is not appealable (paragraphs (c) and (f)).
How long is the Medicare reenrollment bar?
Usually 1 to 10 years. The bar "lasts a minimum of 1 year, but not greater than 10 years (except for the situations described in paragraphs (c)(2) and (3) of this section), depending on the severity of the basis for revocation" (42 CFR 424.535, paragraph (c)(1)(i)). CMS may add up to 3 more years for circumvention and impose up to 20 years on a second revocation, and no bar applies to an (a)(1) revocation for failing to respond on time to a revalidation or information request (paragraphs (c)(2), (c)(3), (c)(1)(ii)).
When does a Medicare revocation take effect?
Usually 30 days after CMS or the CMS contractor mails notice of its determination (42 CFR 424.535, paragraph (g)(1)). Paragraphs (a)(8)(iii) and (g)(2) set other dates, often earlier, for listed grounds, such as the date the certification statement was signed on an application with false or misleading information, and paragraph (g)(3) uses the enrollment effective date when the triggering action came before that date.
Can we submit a corrective action plan after a revocation?
Only for a revocation for noncompliance under 42 CFR 424.535(a)(1) (42 CFR 405.809, paragraph (a)(1)). CMS instructs its contractors that a corrective action plan "Must be received within 35 calendar days from the date of the initial determination," and where a revocation rests on several grounds, a plan may be accepted only as to the (a)(1) ground (CMS Medicare Program Integrity Manual, chapter 10, section 10.6.18(B)(2)).
How many chances do we get to submit a corrective action plan?
One. A provider "has only one opportunity to correct all deficiencies that served as the basis of its revocation through a corrective action plan" (42 CFR 405.809, paragraph (a)(2)). If the evidence falls short, the manual says the contractor need not ask for missing documentation and denies the plan (CMS Medicare Program Integrity Manual, chapter 10, section 10.6.18(B)(5)).
Does a corrective action plan stop the reconsideration deadline?
No. The manual says the time to request reconsideration "continues to run even though the MAC has received a CAP and is reviewing the CAP," and the request must arrive within 65 days of the date of the initial determination (CMS Medicare Program Integrity Manual, chapter 10, section 10.6.18(B)(6)). The regulation allows 60 days from receipt, presumed 5 days after the notice date unless shown otherwise; CMS extends the time if you show good cause (42 CFR 498.22, paragraphs (b)(3) and (d)).
Is Medicare payment made while we appeal a revocation?
No. "Payment is not made during the appeals process" (42 CFR 424.545, paragraph (a)(2)). If the revocation is overturned, unpaid claims for services furnished during the overturned period may be resubmitted.