A practice manager called us in the second week of January last year because every claim for one of her physicians had started denying with CO-B7. The physician had not changed anything. Her Medicare revalidation had been due in November, the letter had gone to a previous practice address, and the enrollment was deactivated on January 3. It took seven weeks to reactivate, and Medicare allows retroactive billing only back to the date the reactivation application was received, so about a month of that physician's Medicare work was never paid.
That story is common enough that we now treat September as credentialing month for every practice we support. The processing times don't leave room to react in December. Commercial recredentialing takes 60 to 120 days once the payer has a complete file. Medicare revalidations are faster but still weeks. If something needs to be right on January 1, the work starts now.
Key takeaways
- Four things converge on January 1: contract amendments, Medicare Advantage network changes, three-year recredentialing cycles and any enrollment that lapsed quietly during the year.
- Medicare revalidation is the failure with the highest cost, because a deactivation stops every claim and reactivation is not fully retroactive.
- CAQH attestations, correspondence addresses and notification emails cause most commercial recredentialing stalls; all three are fixable in an afternoon.
- Every provider should have one file that a stranger could pick up in a day, with every date, number and expiration in it.
Why January specifically
Four things converge at the start of the year. Commercial contracts commonly renew on a calendar-year basis, and amendments to fee schedules and participation terms take effect January 1. Medicare Advantage networks change with the plan year, which means the plans your patients pick during open enrollment (October 15 to December 7) become effective January 1 and your participation status with each of them is suddenly visible in the eligibility response. Payers that recredential on a three-year cycle often align that cycle to the year, so a share of every practice's providers is due in the same quarter. And any provider who lapsed quietly during the year finds out when the deductible-reset volume arrives and the denials arrive with it.
The September review, in order
| Check | Where | Why now |
|---|---|---|
| Medicare revalidation due dates for every provider and the group | PECOS, or the Medicare revalidation lookup tool | Due dates listed as "TBD" can appear with a few months' notice; anything due before March should be submitted this month |
| CAQH ProView attestation date and document expirations | CAQH ProView | Attestation lapses every 120 days; payers pull the profile during recredentialing and reject stale ones |
| Commercial recredentialing schedule | Each payer's provider portal or the last approval letter | Three-year cycles mean roughly a third of your providers are due each year; find out which ones |
| Contract renewal and amendment notices | Contract file, payer correspondence since June | Fee schedule and term changes for January 1 usually arrive with 60 to 90 days' notice, often to a mailing address nobody checks |
| State license, DEA, board certification and malpractice expirations through June 2027 | Provider file | Any document that expires during a recredentialing review generates a request and restarts part of the clock |
| Medicaid managed care plan enrollment | State portal and each MCO | Plan assignments change with the calendar year in many states, and MCO enrollment is separate from state Medicaid enrollment |
| NPPES data for every provider | NPPES | Practice location, taxonomy and mailing address drive where notices go; the January story above started here |
Work the table top to bottom, one provider at a time, and record the answer to each row with a date and a source. "Checked PECOS September 8, revalidation due 2029-04-30" is a record. "Fine" is not. When the same person runs the same table in December, the differences between the two passes are the work list.
Revalidation: the one that hurts the most
Medicare requires revalidation every five years for most providers and every three years for DMEPOS suppliers. The due date is posted in PECOS and in the public lookup tool, and it can change from "TBD" to a firm date with roughly six months of warning. We check it for every provider every quarter, but September is when we act on anything due through March, because a revalidation submitted in September is processed before the holiday backlog and any development request can be answered in October.
Here is how the timeline runs when it goes badly. A due date of November 30 appears in the lookup tool in early June. The Medicare Administrative Contractor mails a notice two to three months ahead, to the correspondence address in PECOS. Nobody sees it. The due date passes. The contractor may hold claims or, after the grace period it allows, deactivate the enrollment, and claims begin denying with CO-B7 or a remark about an inactive provider number. The practice submits a reactivation, which is processed as a new application and can take 45 to 90 days depending on the contractor and the queue. Billing privileges resume from the date the contractor received the reactivation, not the date of deactivation. Everything in the gap is lost. The same timeline, started in September with the notice in hand, ends with a confirmation letter in October and nothing lost.
Two habits prevent most revalidation problems. The correspondence address in PECOS must be one that a living person in the practice reads every week. And the group's revalidation is separate from each provider's; a group deactivation stops every claim for every provider who reassigns benefits to it, so the group record is the first row on the list, not an afterthought.
Commercial recredentialing and the CAQH trap
Most commercial payers recredential on a three-year cycle and pull the provider's data from CAQH ProView. The failure mode is boring: the profile's attestation lapsed, a malpractice face sheet expired in July, the work history still ends at the previous job. The payer sends a request to the provider's email on file, which is often a personal address, and the recredentialing stalls. Some payers terminate participation for non-response, and the practice finds out when claims start paying at out-of-network rates or not at all.
Our September rule is simple: re-attest every profile in the practice this month regardless of when it last happened, upload every document that expires before July, and change the notification email to a shared credentialing inbox. While you are in the profile, check the practice locations and the "authorize" list, because a payer that is not authorized to view the profile cannot recredential from it and will send a paper application instead, which adds weeks.
Contract changes you should be reading
Amendment notices for January 1 are arriving now. Read them for three things. The fee schedule reference (is it still a percentage of the current-year Medicare fee schedule, and which year's conversion factor does it point at). Changes to the timely filing or appeal windows, which change how your denial team works. And changes to the products the contract covers; a commercial contract that now includes a Medicare Advantage or exchange product changes your patient mix in January whether you noticed or not.
Several health systems have announced they are leaving specific Medicare Advantage networks at the end of this year. Independent practices are usually not the ones terminating, but if the hospital you admit to has left a plan, your patients in that plan will be asking you what happens to their referrals and procedures in January. Knowing your own participation status with each plan is the first step to answering them.
New plans for 2027
Plan filings for 2027 are final, and CMS publishes the plan data files around the end of September, just before open enrollment. If a new Medicare Advantage or Medicaid managed care plan is entering your county, September is the month to request participation, because a request that goes in now might be effective by the time members start arriving in January. A request submitted in January is effective in spring at the earliest, and there is rarely retroactive coverage for commercial and Advantage plans. Check your state's Medicaid managed care assignments too; several states rotate or add plans with the calendar year, and MCO enrollment is a separate application from the state Medicaid enrollment that many practices assume covers it.
The file you should be able to produce
For every provider, one folder with the current CAQH attestation date, the Medicare revalidation due date and PTAN, the effective date and provider number with each commercial payer, the recredentialing due date with each, every document with its expiration, and the contract amendments that apply. If your credentialing coordinator left tomorrow, this folder is what lets someone else pick up in a day. In our credentialing service this is the file we maintain, and the dashboard shows each item and its next date. Practices doing it themselves can build the same thing in a spreadsheet; the format matters less than the discipline of keeping it current.
Questions we hear
A payer told us recredentialing is not due until 2028. Can we skip that payer this year?
Skip the recredentialing, not the review. The CAQH attestation still lapses every 120 days, the documents still expire, and the contract amendment for January still needs reading. Record the 2028 date in the file with the name of the person who gave it to you.
Our new nurse practitioner starts in November. Is September too early?
It is later than we would like. Medicare enrollment for a new provider is often 30 to 60 days, and commercial payers commonly take 90 or more, so a November start with applications filed in September usually means a few weeks of visits that can only be billed to the payers that have finished. Start the day the offer is signed, and hold the schedule to payers that are effective until the rest come through.
What if a revalidation notice arrives for a provider who left the practice?
Terminate the reassignment in PECOS rather than ignoring the notice. An ignored revalidation for a departed provider can still trigger a review of the group record, and an open reassignment is a compliance exposure if that provider bills elsewhere.
What to do this month
- Pull Medicare revalidation due dates for every provider and the group. Submit anything due before March 31, 2027.
- Re-attest every CAQH profile and upload documents expiring before July 2027. Change the notification email to a shared inbox.
- Ask each of your top eight payers, in writing, for the recredentialing due date of every provider. Record the answers.
- Read every contract amendment received since June for fee schedule, filing window and product changes. Calendar the effective dates.
- Confirm NPPES and PECOS correspondence addresses are ones someone reads.
- Request participation with any new plan entering your county for 2027.
None of this is difficult. It is simply easier in September than it will be in January, and the practices that do it now are the ones not calling us in the second week of the year.
