Revocation actions. As with suspensions, we have seen a sharp increase in the number of Medicare revocation actions taken over the last year. The reasons for revocation have varied but have typically been associated with:
Failure to meet the requirements set out under the Medicare participation agreement (such as failure to “cooperate”).
Alleged failure to meet one or more of the core requirements set out for a particular type of provider.
And, more recently, the failure of a provider to properly notify CMS that the provider has moved.
Revocation actions are often retroactive for at least a period of months.