Most of Medicare's posted revalidation deadlines are already past due, 2026

Every provider and supplier enrolled in Medicare has to check back in. On a fixed cycle — five years for most, three for durable-medical-equipment suppliers — each enrollment must be revalidated: the provider reconfirms its name, address, ownership, and practice information so CMS's enrollment file stays current. CMS tracks the schedule in a public roster, the Revalidation Due Date List, published every month through its data catalog. For each enrollment the file shows one of two things: an assigned due date, or "TBD." Read the latest list and a single fact stands out — among the enrollments that do carry a posted deadline, most of those deadlines have already passed.

Most posted deadlines are already in the past

CMS assigns a due date only to enrollments coming due soon, so most of the 2.9 million records read "TBD." But of the 261,878 enrollments that carry an assigned revalidation due date, 217,968 — 83.2% — show a date already in the past as of the June 15, 2026 snapshot read. Those overdue enrollments span 193,508 distinct NPIs, and the oldest deadline on the list dates to July 31, 2023, nearly three years before the snapshot.

Source: CMS Revalidation Due Date List, by enrollment type, May 2026 release, overdue measured as of 2026-06-15.

The "share dated" column is the key to reading the rest of the file. Because CMS only posts a date when revalidation is near, the dated column is the active queue, not the enrollment base — and across all three enrollment types, the large majority of that queue is already past its date.

A revalidation due date is a calendar control, not a verdict. A date in the past records that a provider's periodic enrollment check-in has come due and not yet cleared — it says nothing about whether that provider is eligible, billing correctly, or delivering good care.

The backlog stretches back to 2023

The overdue dates are not bunched at the edge of the window. 187,129 of the overdue enrollments — 86% of them — carry a due date from a prior calendar year (2023, 2024, or 2025), and every one is still on the published list.

Source: CMS Revalidation Due Date List, dated enrollments by the calendar year of the due date, May 2026 release.

Any due date in 2023, 2024, or 2025 is in the past by definition for a 2026 snapshot, so those three years are 100% overdue — they account for the bulk of the backlog. The 2024 cohort alone, 84,598 enrollments, is larger than any single full year before it. Only the 2026 column splits: 30,839 of its 74,749 dates have already passed, while the rest are the genuinely upcoming deadlines — the part of the queue working as designed.

It is an organizational backlog, not an individual one

The overdue cohort is overwhelmingly organizational. 95.0% of overdue enrollments carry an organization name — group practices, pharmacies, agencies, and suppliers — rather than belonging to an individual practitioner. One category dominates.

Source: CMS Revalidation Due Date List, overdue enrollments by enrollment specialty, the eight largest categories, May 2026 release.

Clinic/Group Practice accounts for 101,391 overdue enrollments on its own — 46.5% of the entire overdue cohort. Add pharmacies and the two roster-billing categories (mass immunization and centralized flu billers, a combined 25,626) and four organizational enrollment types make up roughly seven in ten overdue records. Individual practitioner specialties — podiatry, optometry, nurse practitioners — appear far down the list. The revalidation queue is, in effect, a queue of organizations.

Why DME suppliers crowd the active queue

One structural pattern explains the lopsided "share dated" column above. Durable-medical-equipment suppliers revalidate every three years; almost everyone else revalidates every five. A shorter cycle means a larger fraction of DME enrollments come due in any given window — which is exactly what the file shows: 78.4% of DME enrollments carry a posted due date, against just 6.8% of Non-DME Part B enrollments.

That difference is a feature of the schedule, not a sign that DME suppliers are less compliant. CMS applies the tighter three-year cadence to DMEPOS precisely because it is a category it monitors closely for enrollment integrity. The effect is that DME suppliers are perpetually over-represented in the active revalidation queue relative to their small share of total enrollments — 71,401 DME enrollments produce nearly as many dated records as the 2.76 million Non-DME Part B enrollments do.

Where the overdue enrollments are

Rolled up by state, the overdue counts track the largest Medicare states, while the highest overdue shares sit in a different set.

Source: CMS Revalidation Due Date List, the eight states with the most overdue enrollments, May 2026 release.

Texas leads on raw count with 27,670 overdue enrollments, followed by California, New York, and Florida — the four largest Medicare states. But the overdue share of each state's dated queue is highest elsewhere: Georgia at 93.3%, North Carolina 92.1%, Ohio 91.6%, and Illinois 91.5% all run well above the national 83.2%, while California (77.0%) and New York (78.3%) sit below it. The share differences reflect how recently each state's cohort of dates was assigned, not a ranking of state performance.

What one row actually is

Each row in cms_revalidation_due_dates is one Medicare enrollment: an NPI, the enrolling provider or organization, its state and enrollment specialty, the enrollment type, and either an assigned revalidation due date or "TBD." The file is the current published roster, not a history — CMS refreshes it monthly, and an enrollment's date moves back to "TBD" once it revalidates and the next cycle is years away. Counting and grouping these rows is the entire method here. Every figure in this study is a count or percentage at the enrollment-type, year, specialty, or state level. No provider — individual or organization — is named, ranked, or scored.

Methodology

All figures are direct aggregations over the cms_revalidation_due_dates table, populated from the CMS Revalidation Due Date List public-use file published through the CMS data catalog (data.cms.gov, Medicare Provider/Supplier Enrollment). The table holds 2,900,588 enrollment records across 2,422,395 distinct NPIs, 56 states/territories, and 533 enrollment specialties; May 2026 release (.../2026-05/.../revalidation_base.csv), ingested 2026-06-14; public, read-only; license US-Government-Works. CMS republishes the full list monthly, so figures advance with each refresh.

"Dated" enrollments are those where revalidation_due_date is not null — CMS posts a date only for enrollments due within roughly the next six months, so the 261,878 dated records are the active revalidation queue rather than the full enrollment base. "Overdue" is defined as revalidation_due_date < DATE '2026-06-15', the snapshot read date; the single total-overdue figure (217,968) is stated as of that date, while the prior-calendar-year counts (2023–2025, totaling 187,129) are past for any read date in 2026 and are stable. Because these are direct counts and ratios over a published file, every figure is exact as of the snapshot rather than estimated. Methodology version: cms-revalidation/v1. The source-provenance contract is documented in the provenance methodology.

Limitations

• An administrative timing signal, not a fraud, eligibility, or quality finding. A past-due revalidation date records that an enrollment's periodic check-in has come due and not yet cleared in the published file. It is unrelated to exclusion, sanction, billing correctness, or any assessment of care, and CMS routinely continues an enrollment past its due date while a revalidation is processed. This study draws no inference about any provider.
• Not the same as deactivation. A past-due date is an enrollment-maintenance deadline, not a loss of billing privileges. CMS deactivates an enrollment for non-response only after a separate notice-and-process step, which this file does not record. An overdue record may belong to a provider that is fully active and billing.
• The dated rows are a queue, not the enrollment base. Because 91.0% of records read "TBD," every share in this study is computed over the 261,878 enrollments that carry a posted date — the active revalidation window — not over all 2.9 million enrollments. The "9.0% of all enrollments are past due" reading would understate the point; the relevant denominator is the assigned-date queue.
• The file is a current roster, not a history. CMS refreshes the list monthly and an enrollment's date returns to "TBD" once it revalidates. The counts describe enrollments currently showing a past date, not the full historical flow of every revalidation ever due.
• Point-in-time, not a trend model. Figures reflect the single May 2026 release read as of June 15, 2026. The total-overdue count grows with any later read date as more posted dates pass; this study does not model change over time.
• Aggregate and group-level only. Every figure is a count or percentage at the enrollment-type, due-year, specialty, or state level. No individual provider or organization is named, ranked, or scored, and the enrollment-to-entity-graph link is not used here.

Sources

• CMS — Revalidation Due Date List — the monthly public-use file behind every figure in this study.
• CMS — Revalidations (provider enrollment) — CMS's description of the revalidation cycle, the five-year and three-year cadences, and how due dates are assigned and published.
• 42 CFR §424.515 — Maintaining Medicare enrollment — the regulation requiring periodic resubmission and recertification of enrollment information.

The companion dataset page for CMS PECOS lists the full schema and refresh cadence. This is the enrollment-maintenance mirror of the changing shape of Medicare enrollment and of the March 2026 spike in enrollment deactivations; for the program-integrity end of the same system see the providers excluded from Medicare yet still enrolled and the excluded providers who keep order-and-refer eligibility, and for where those enrolled providers cluster and opt out, home health and DME market saturation and who opts out of Medicare entirely.