Key findings
83.2%
of the 261,878 Medicare enrollments CMS has assigned a revalidation due date carry a deadline already in the past as of June 15, 2026 — 217,968 enrollments across 193,508 distinct NPIs, the oldest dated July 31, 2023
cms-pecos · CMS
cms-pecos · CMS
187,129
of the overdue enrollments carry a due date from a prior calendar year — 47,218 from 2023, 84,598 from 2024, and 55,313 from 2025 — every one of which is still on the published list; the 2024 cohort alone is larger than any single full year before it
cms-pecos · CMS
cms-pecos · CMS
95.0%
of overdue enrollments carry an organization name — 207,177 of 217,968; Clinic/Group Practice alone is 46.5% of the overdue cohort (101,391 enrollments), followed by pharmacies (31,152) and roster-billing flu/immunization enrollments (25,626 combined)
cms-pecos · CMS
cms-pecos · CMS
78.4%
of durable-medical-equipment supplier enrollments fall inside the posted due-date window, against just 6.8% of Non-DME Part B enrollments — the gap reflects the 3-year DMEPOS revalidation cycle versus 5 years for everyone else, not a difference in compliance
cms-pecos · CMS
cms-pecos · CMS
91.0%
of the 2,900,588 enrollment records show no due date at all ("TBD"); 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, not the full enrollment base
cms-pecos · CMS
cms-pecos · CMS
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.
| Enrollment type | Enrollments | With a due date | Share dated | Past due |
|---|---|---|---|---|
| Non-DME Part B | 2,757,567 | 187,722 | 6.8% | 157,201 |
| DME suppliers | 71,401 | 55,957 | 78.4% | 44,991 |
| Part A | 71,620 | 18,199 | 25.4% | 15,776 |
| All enrollments | 2,900,588 | 261,878 | 9.0% | 217,968 |
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.
| Due-date year | Enrollments dated | Past due |
|---|---|---|
| 2023 | 47,218 | 47,218 |
| 2024 | 84,598 | 84,598 |
| 2025 | 55,313 | 55,313 |
| 2026 | 74,749 | 30,839 |
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. 207,177 of the 217,968 overdue enrollments — 95.0% — carry an organization name: group practices, pharmacies, agencies, and suppliers, rather than an individual practitioner. One category dominates.
| Enrollment specialty | Past due | Share of overdue |
|---|---|---|
| Clinic/Group Practice | 101,391 | 46.5% |
| Pharmacy | 31,152 | 14.3% |
| Mass Immunization (Roster Biller Only) | 14,823 | 6.8% |
| Centralized Flu Biller | 10,803 | 5.0% |
| Home Health Agency | 4,271 | 2.0% |
| Physical/Occupational Therapy Group | 3,986 | 1.8% |
| Ambulance Service Supplier | 3,938 | 1.8% |
| Medical Supply Company | 3,286 | 1.5% |
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.
| State | With a due date | Past due | Overdue share |
|---|---|---|---|
| Texas | 32,860 | 27,670 | 84.2% |
| California | 20,974 | 16,150 | 77.0% |
| New York | 13,986 | 10,948 | 78.3% |
| Florida | 13,166 | 10,752 | 81.7% |
| Illinois | 10,981 | 10,044 | 91.5% |
| North Carolina | 10,209 | 9,402 | 92.1% |
| Ohio | 9,400 | 8,613 | 91.6% |
| Georgia | 8,838 | 8,249 | 93.3% |
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.
Frequently asked questions
- What is Medicare provider revalidation?
- Revalidation is the periodic recertification every Medicare-enrolled provider and supplier must complete to confirm its enrollment information is current. Most enrollments revalidate every five years; durable-medical-equipment (DMEPOS) suppliers revalidate every three. CMS assigns each enrollment a due date and publishes those dates in the monthly Revalidation Due Date List.
- What does it mean for a revalidation due date to be 'past due'?
- It means CMS posted a deadline for that enrollment and the snapshot still shows that date in the past. It is an administrative timing signal — a check-in that has come due and not yet cleared in the published file. It is not a finding of fraud, a loss of eligibility, or any judgment about the provider's billing or care. CMS can and does continue an enrollment past its due date while a revalidation is in process.
- Why do most enrollments show 'TBD' instead of a date?
- Because CMS posts an assigned due date only for enrollments due within roughly the next six months. Everything else reads 'TBD'. In this file 2,638,710 of 2,900,588 records (91.0%) are TBD, so the 261,878 dated records are the active revalidation queue at the time of the snapshot, not the whole Medicare enrollment base.
- Which kinds of providers have the most overdue revalidations?
- Organizational enrollments, not individual clinicians. 207,177 of 217,968 overdue enrollments — 95.0% — carry an organization name. The single largest category is Clinic/Group Practice at 101,391 enrollments — 46.5% of the overdue cohort — followed by pharmacies, roster-billing flu and immunization enrollments, home health agencies, and equipment and ambulance suppliers.
- Does an overdue revalidation date mean a provider can't bill Medicare?
- No. The due date is an enrollment-maintenance deadline, separate from billing privileges. A provider whose revalidation is past due in this file may still be actively enrolled and billing; CMS deactivates an enrollment for non-response only after a separate notice-and-process step. This study reads the published due-date file and makes no claim about any provider's billing status.
- Can I reproduce these figures?
- Yes. Every number is a direct count over the public cms_revalidation_due_dates table — CMS's Revalidation Due Date List, May 2026 release — with no modeling, computed as of the snapshot read date of June 15, 2026. The exact SQL for the dated/overdue split, the year-by-year aging, the specialty concentration, and the state breakdown is published in the reproducibility block below.
Who uses this data
The source data behind this study is public
Compliance teams, journalists, and researchers work from the same federal source families cited above — queried by NPI or facility identifier through Fonteum’s open dataset pages and API. Every figure traces to a frozen, downloadable snapshot you can reproduce yourself.
Datasets used
Reproducibility
Every claim, reproducible
The SQL
-- Most of Medicare's POSTED revalidation deadlines are already past due.
-- Fully reproducible query.
--
-- Question: every Medicare provider and supplier must revalidate its
-- enrollment on a fixed cycle (5 years for most, 3 years for DMEPOS
-- suppliers). CMS publishes the Revalidation Due Date List — for each
-- enrollment, either an assigned due date or "TBD". Of the enrollments CMS
-- has actually assigned a due date, how many of those deadlines have already
-- passed, how old is the backlog, and what kind of enrollment does it
-- concentrate in? The lead figure: of the 261,878 enrollments carrying an
-- assigned due date, 217,968 — 83.2% — show a date already in the past as of
-- 2026-06-15. A revalidation due date is an administrative calendar control;
-- a date in the past is a TIMING signal, NOT a fraud, ineligibility, or
-- quality signal of any kind.
--
-- Source:
-- public.cms_revalidation_due_dates — CMS "Revalidation Due Date List",
-- published monthly via the CMS data catalog (data.cms.gov, Medicare
-- Provider/Supplier Enrollment). 2,900,588 enrollment records across
-- 2,422,395 distinct NPIs; May 2026 release
-- (.../2026-05/.../revalidation_base.csv), ingested 2026-06-14. Public,
-- read-only. License: US-Government-Works (17 U.S.C. Sec. 105).
-- methodology_version = 'cms-revalidation/v1'.
--
-- Universe: this study reads the published file AS A WHOLE — every row is one
-- Medicare enrollment record. CMS posts an assigned due date only for
-- enrollments due within roughly the next six months; all others read
-- "TBD" (stored as NULL here). The dated rows are therefore the active
-- revalidation queue; the file is a point-in-time snapshot, not a trend.
--
-- As-of date: "overdue" = revalidation_due_date < DATE '2026-06-15', the
-- snapshot read date. Figures that depend on the as-of date (the total
-- overdue count) are stated as of that date; the prior-calendar-year
-- counts (2023-2025) are past for any read date in 2026 and are stable.
-- No individual provider is named, ranked, or scored anywhere below.
-- ============================================================================
-- (1) Universe reconciliation — the published file at a glance.
-- ============================================================================
-- audit-claim: universe
SELECT
count(*) AS enrollments,
count(DISTINCT npi) AS distinct_npi,
count(*) FILTER (WHERE revalidation_due_date IS NULL) AS tbd_no_date,
round(100.0 * count(*) FILTER (WHERE revalidation_due_date IS NULL) / count(*), 1)
AS tbd_pct,
count(*) FILTER (WHERE revalidation_due_date IS NOT NULL) AS dated,
round(100.0 * count(*) FILTER (WHERE revalidation_due_date IS NOT NULL) / count(*), 1)
AS dated_pct,
count(DISTINCT enrollment_state) AS states,
count(DISTINCT enrollment_specialty) AS specialties,
min(revalidation_due_date) AS earliest_due,
max(revalidation_due_date) AS latest_due
FROM public.cms_revalidation_due_dates;
-- enrollments 2,900,588 · distinct_npi 2,422,395 · tbd_no_date 2,638,710 (91.0%)
-- dated 261,878 · states 56 · specialties 533
-- earliest_due 2023-07-31 · latest_due 2026-11-30
-- ============================================================================
-- (2) HEADLINE: of the enrollments CMS has assigned a due date, what share is
-- already past due as of the snapshot read date (2026-06-15)?
-- ============================================================================
-- audit-claim: overdue-headline
SELECT
count(*) FILTER (WHERE revalidation_due_date IS NOT NULL) AS dated,
count(*) FILTER (WHERE revalidation_due_date < DATE '2026-06-15') AS overdue,
round(100.0 * count(*) FILTER (WHERE revalidation_due_date < DATE '2026-06-15')
/ count(*) FILTER (WHERE revalidation_due_date IS NOT NULL), 1) AS overdue_pct_of_dated,
count(DISTINCT npi) FILTER (WHERE revalidation_due_date < DATE '2026-06-15')
AS overdue_distinct_npi
FROM public.cms_revalidation_due_dates;
-- dated 261,878 · overdue 217,968 · overdue_pct_of_dated 83.2% · overdue_distinct_npi 193,508
-- ============================================================================
-- (3) The dated/overdue split by enrollment type. DME suppliers revalidate on
-- a 3-year cycle (vs 5 years for everyone else), so a far larger share of
-- DME enrollments sit inside the posted due-date window: 78.4% of DME
-- enrollments are dated, against 6.8% of Non-DME Part B.
-- ============================================================================
-- audit-claim: enrollment-type-vector
SELECT
provider_type_text,
count(*) AS enrollments,
count(*) FILTER (WHERE revalidation_due_date IS NOT NULL) AS dated,
round(100.0 * count(*) FILTER (WHERE revalidation_due_date IS NOT NULL)
/ count(*), 1) AS dated_pct,
count(*) FILTER (WHERE revalidation_due_date < DATE '2026-06-15') AS overdue
FROM public.cms_revalidation_due_dates
GROUP BY provider_type_text
ORDER BY enrollments DESC;
-- Non-DME Part B 2,757,567 · dated 187,722 ( 6.8%) · overdue 157,201
-- Part A 71,620 · dated 18,199 (25.4%) · overdue 15,776
-- DME 71,401 · dated 55,957 (78.4%) · overdue 44,991
-- ============================================================================
-- (4) HOW OLD the backlog is — overdue enrollments by the calendar year the
-- due date falls in. Every dated record from 2023, 2024 and 2025 is past
-- due (187,129 in total, the oldest 2023-07-31); the 2026 column splits
-- into the genuinely past-due (30,839) and the still-future window.
-- ============================================================================
-- audit-claim: due-year-vector
SELECT
extract(year FROM revalidation_due_date)::int AS due_year,
count(*) AS dated,
count(*) FILTER (WHERE revalidation_due_date < DATE '2026-06-15') AS overdue
FROM public.cms_revalidation_due_dates
WHERE revalidation_due_date IS NOT NULL
GROUP BY due_year
ORDER BY due_year;
-- 2023 47,218 · overdue 47,218
-- 2024 84,598 · overdue 84,598
-- 2025 55,313 · overdue 55,313
-- 2026 74,749 · overdue 30,839
-- (prior-calendar-year overdue, 2023-2025 = 187,129; total overdue = 217,968)
-- Direct aggregate behind the "86%" and "100% overdue" public displays.
-- audit-claim: prior-year-summary
SELECT
count(*) FILTER (
WHERE revalidation_due_date >= DATE '2023-01-01'
AND revalidation_due_date < DATE '2026-01-01'
AND revalidation_due_date < DATE '2026-06-15'
) AS prior_year_overdue,
count(*) FILTER (WHERE revalidation_due_date < DATE '2026-06-15') AS overdue,
round(
100.0 * count(*) FILTER (
WHERE revalidation_due_date >= DATE '2023-01-01'
AND revalidation_due_date < DATE '2026-01-01'
AND revalidation_due_date < DATE '2026-06-15'
) / count(*) FILTER (WHERE revalidation_due_date < DATE '2026-06-15')
) AS prior_year_pct_of_overdue,
round(
100.0 * count(*) FILTER (
WHERE revalidation_due_date >= DATE '2023-01-01'
AND revalidation_due_date < DATE '2026-01-01'
AND revalidation_due_date < DATE '2026-06-15'
) / count(*) FILTER (
WHERE revalidation_due_date >= DATE '2023-01-01'
AND revalidation_due_date < DATE '2026-01-01'
), 1
) AS prior_year_overdue_pct
FROM public.cms_revalidation_due_dates;
-- prior_year_overdue 187,129 · overdue 217,968 · share 86% · prior years 100% overdue
-- ============================================================================
-- (5) WHAT KIND of enrollment the backlog is — overdue cohort by enrollment
-- specialty, top 12. It is overwhelmingly ORGANIZATIONAL: 95.0% of overdue
-- enrollments carry an organization name (group practices, pharmacies,
-- agencies, suppliers) rather than an individual; Clinic/Group Practice
-- alone is 46.5% of the overdue cohort.
-- ============================================================================
-- audit-claim: specialty-vector
SELECT
enrollment_specialty,
count(*) FILTER (WHERE revalidation_due_date < DATE '2026-06-15') AS overdue,
round(100.0 * count(*) FILTER (WHERE revalidation_due_date < DATE '2026-06-15')
/ (SELECT count(*) FROM public.cms_revalidation_due_dates
WHERE revalidation_due_date < DATE '2026-06-15'), 1) AS pct_of_overdue
FROM public.cms_revalidation_due_dates
WHERE enrollment_specialty IS NOT NULL AND enrollment_specialty <> ''
GROUP BY enrollment_specialty
ORDER BY overdue DESC
LIMIT 12;
-- Clinic/Group Practice 101,391 46.5%
-- Pharmacy 31,152 14.3%
-- Mass Immunization (Roster Biller Only) 14,823 6.8%
-- Centralized Flu Biller 10,803 5.0%
-- Home Health Agency 4,271 2.0%
-- Physical/Occupational Therapy Group 3,986 1.8%
-- Ambulance Service Supplier 3,938 1.8%
-- Medical Supply Company 3,286 1.5%
-- Federally Qualified Health Center 2,830 1.3%
-- Physician - Podiatry 2,623 1.2%
-- Independent Clinical Laboratory 2,619 1.2%
-- Ambulatory Surgical Center 2,247 1.0%
-- (organization-named share of overdue = 207,177 of 217,968 = 95.0%)
-- Organization-name share of the overdue cohort, returned directly.
-- audit-claim: organization-name-share
SELECT
count(*) FILTER (
WHERE revalidation_due_date < DATE '2026-06-15'
) AS overdue,
count(*) FILTER (
WHERE revalidation_due_date < DATE '2026-06-15'
AND nullif(btrim(organization_name), '') IS NOT NULL
) AS organization_named,
round(
100.0 * count(*) FILTER (
WHERE revalidation_due_date < DATE '2026-06-15'
AND nullif(btrim(organization_name), '') IS NOT NULL
) / nullif(count(*) FILTER (
WHERE revalidation_due_date < DATE '2026-06-15'
), 0),
1
) AS organization_named_pct
FROM public.cms_revalidation_due_dates;
-- overdue 217,968 · organization_named 207,177 · organization_named_pct 95.0
-- The four organizational categories behind "roughly seven in ten."
-- audit-claim: top-four-concentration
WITH overdue AS (
SELECT enrollment_specialty
FROM public.cms_revalidation_due_dates
WHERE revalidation_due_date < DATE '2026-06-15'
)
SELECT
count(*) FILTER (WHERE enrollment_specialty = 'Clinic/Group Practice')
AS clinic,
count(*) FILTER (WHERE enrollment_specialty = 'Pharmacy') AS pharmacy,
count(*) FILTER (WHERE enrollment_specialty IN (
'Mass Immunization (Roster Biller Only)', 'Centralized Flu Biller'
)) AS roster_billing_combined,
count(*) FILTER (WHERE enrollment_specialty IN (
'Clinic/Group Practice', 'Pharmacy',
'Mass Immunization (Roster Biller Only)', 'Centralized Flu Biller'
)) AS top_four_combined,
round(100.0 * count(*) FILTER (WHERE enrollment_specialty IN (
'Clinic/Group Practice', 'Pharmacy',
'Mass Immunization (Roster Biller Only)', 'Centralized Flu Biller'
)) / count(*), 1) AS top_four_pct_of_overdue
FROM overdue;
-- clinic 101,391 · pharmacy 31,152 · roster billing 25,626
-- top four 158,169 of 217,968 = 72.6% ("roughly seven in ten")
-- ============================================================================
-- (6) WHERE the overdue enrollments are — top 10 states by overdue count, with
-- each state's own overdue share of its dated enrollments. The big states
-- lead on count (TX 27,670); several mid-size states show the highest
-- overdue shares (GA 93.3%, NC 92.1%, OH 91.6%, IL 91.5%).
-- ============================================================================
-- audit-claim: state-vector
SELECT
enrollment_state,
count(*) FILTER (WHERE revalidation_due_date IS NOT NULL) AS dated,
count(*) FILTER (WHERE revalidation_due_date < DATE '2026-06-15') AS overdue,
round(100.0 * count(*) FILTER (WHERE revalidation_due_date < DATE '2026-06-15')
/ NULLIF(count(*) FILTER (WHERE revalidation_due_date IS NOT NULL), 0), 1)
AS overdue_pct_of_dated
FROM public.cms_revalidation_due_dates
WHERE enrollment_state IS NOT NULL
GROUP BY enrollment_state
ORDER BY overdue DESC
LIMIT 10;
-- TX 32,860 dated · 27,670 overdue · 84.2% · CA 20,974 · 16,150 · 77.0%
-- NY 13,986 · 10,948 · 78.3% · FL 13,166 · 10,752 · 81.7%
-- IL 10,981 · 10,044 · 91.5% · NC 10,209 · 9,402 · 92.1%
-- OH 9,400 · 8,613 · 91.6% · GA 8,838 · 8,249 · 93.3%
-- MI 9,107 · 7,108 · 78.0% · PA 8,840 · 6,970 · 78.8%The snapshot
| dataset_id | cms-pecos |
| snapshot_date | 2026-06-15 |
| slsa_provenance_url | pending - publishes with the SLSA provenance generator (not yet live) |
The JOINs
universe: the published file as a whole -- 2,900,588 enrollment records, 2,422,395 distinct NPIs, May 2026 release dated = revalidation_due_date IS NOT NULL -- 261,878 records (TBD/NULL = 2,638,710, 91.0%) overdue = revalidation_due_date < DATE '2026-06-15' (snapshot read date) -- 217,968 of 261,878 dated = 83.2%; 193,508 distinct NPIs aging: GROUP BY extract(year FROM revalidation_due_date) -- 2023-2025 due dates = 187,129, all past due; 2026 = 30,839 of 74,749 type split by provider_type_text -- DME 78.4% dated (3-yr cycle) vs Non-DME Part B 6.8% (5-yr) concentration: GROUP BY enrollment_specialty -- Clinic/Group Practice 101,391 = 46.5% of overdue; org-named = 95.0% geography: GROUP BY enrollment_state -- TX 27,670 overdue (most); GA 93.3% / NC 92.1% highest overdue share
The pipeline version
| git_sha | 8c06d24b |
| slsa_provenance | pending - publishes with the SLSA provenance generator (not yet live) |
| methodology_version | cms-revalidation/v1 |
Reproduce this
Run the exact query against the frozen 2026-06-15.
-- Most of Medicare's POSTED revalidation deadlines are already past due.
-- Fully reproducible query.
--
-- Question: every Medicare provider and supplier must revalidate its
-- enrollment on a fixed cycle (5 years for most, 3 years for DMEPOS
-- suppliers). CMS publishes the Revalidation Due Date List — for each
-- enrollment, either an assigned due date or "TBD". Of the enrollments CMS
-- has actually assigned a due date, how many of those deadlines have already
-- passed, how old is the backlog, and what kind of enrollment does it
-- concentrate in? The lead figure: of the 261,878 enrollments carrying an
-- assigned due date, 217,968 — 83.2% — show a date already in the past as of
-- 2026-06-15. A revalidation due date is an administrative calendar control;
-- a date in the past is a TIMING signal, NOT a fraud, ineligibility, or
-- quality signal of any kind.
--
-- Source:
-- public.cms_revalidation_due_dates — CMS "Revalidation Due Date List",
-- published monthly via the CMS data catalog (data.cms.gov, Medicare
-- Provider/Supplier Enrollment). 2,900,588 enrollment records across
-- 2,422,395 distinct NPIs; May 2026 release
-- (.../2026-05/.../revalidation_base.csv), ingested 2026-06-14. Public,
-- read-only. License: US-Government-Works (17 U.S.C. Sec. 105).
-- methodology_version = 'cms-revalidation/v1'.
--
-- Universe: this study reads the published file AS A WHOLE — every row is one
-- Medicare enrollment record. CMS posts an assigned due date only for
-- enrollments due within roughly the next six months; all others read
-- "TBD" (stored as NULL here). The dated rows are therefore the active
-- revalidation queue; the file is a point-in-time snapshot, not a trend.
--
-- As-of date: "overdue" = revalidation_due_date < DATE '2026-06-15', the
-- snapshot read date. Figures that depend on the as-of date (the total
-- overdue count) are stated as of that date; the prior-calendar-year
-- counts (2023-2025) are past for any read date in 2026 and are stable.
-- No individual provider is named, ranked, or scored anywhere below.
-- ============================================================================
-- (1) Universe reconciliation — the published file at a glance.
-- ============================================================================
-- audit-claim: universe
SELECT
count(*) AS enrollments,
count(DISTINCT npi) AS distinct_npi,
count(*) FILTER (WHERE revalidation_due_date IS NULL) AS tbd_no_date,
round(100.0 * count(*) FILTER (WHERE revalidation_due_date IS NULL) / count(*), 1)
AS tbd_pct,
count(*) FILTER (WHERE revalidation_due_date IS NOT NULL) AS dated,
round(100.0 * count(*) FILTER (WHERE revalidation_due_date IS NOT NULL) / count(*), 1)
AS dated_pct,
count(DISTINCT enrollment_state) AS states,
count(DISTINCT enrollment_specialty) AS specialties,
min(revalidation_due_date) AS earliest_due,
max(revalidation_due_date) AS latest_due
FROM public.cms_revalidation_due_dates;
-- enrollments 2,900,588 · distinct_npi 2,422,395 · tbd_no_date 2,638,710 (91.0%)
-- dated 261,878 · states 56 · specialties 533
-- earliest_due 2023-07-31 · latest_due 2026-11-30
-- ============================================================================
-- (2) HEADLINE: of the enrollments CMS has assigned a due date, what share is
-- already past due as of the snapshot read date (2026-06-15)?
-- ============================================================================
-- audit-claim: overdue-headline
SELECT
count(*) FILTER (WHERE revalidation_due_date IS NOT NULL) AS dated,
count(*) FILTER (WHERE revalidation_due_date < DATE '2026-06-15') AS overdue,
round(100.0 * count(*) FILTER (WHERE revalidation_due_date < DATE '2026-06-15')
/ count(*) FILTER (WHERE revalidation_due_date IS NOT NULL), 1) AS overdue_pct_of_dated,
count(DISTINCT npi) FILTER (WHERE revalidation_due_date < DATE '2026-06-15')
AS overdue_distinct_npi
FROM public.cms_revalidation_due_dates;
-- dated 261,878 · overdue 217,968 · overdue_pct_of_dated 83.2% · overdue_distinct_npi 193,508
-- ============================================================================
-- (3) The dated/overdue split by enrollment type. DME suppliers revalidate on
-- a 3-year cycle (vs 5 years for everyone else), so a far larger share of
-- DME enrollments sit inside the posted due-date window: 78.4% of DME
-- enrollments are dated, against 6.8% of Non-DME Part B.
-- ============================================================================
-- audit-claim: enrollment-type-vector
SELECT
provider_type_text,
count(*) AS enrollments,
count(*) FILTER (WHERE revalidation_due_date IS NOT NULL) AS dated,
round(100.0 * count(*) FILTER (WHERE revalidation_due_date IS NOT NULL)
/ count(*), 1) AS dated_pct,
count(*) FILTER (WHERE revalidation_due_date < DATE '2026-06-15') AS overdue
FROM public.cms_revalidation_due_dates
GROUP BY provider_type_text
ORDER BY enrollments DESC;
-- Non-DME Part B 2,757,567 · dated 187,722 ( 6.8%) · overdue 157,201
-- Part A 71,620 · dated 18,199 (25.4%) · overdue 15,776
-- DME 71,401 · dated 55,957 (78.4%) · overdue 44,991
-- ============================================================================
-- (4) HOW OLD the backlog is — overdue enrollments by the calendar year the
-- due date falls in. Every dated record from 2023, 2024 and 2025 is past
-- due (187,129 in total, the oldest 2023-07-31); the 2026 column splits
-- into the genuinely past-due (30,839) and the still-future window.
-- ============================================================================
-- audit-claim: due-year-vector
SELECT
extract(year FROM revalidation_due_date)::int AS due_year,
count(*) AS dated,
count(*) FILTER (WHERE revalidation_due_date < DATE '2026-06-15') AS overdue
FROM public.cms_revalidation_due_dates
WHERE revalidation_due_date IS NOT NULL
GROUP BY due_year
ORDER BY due_year;
-- 2023 47,218 · overdue 47,218
-- 2024 84,598 · overdue 84,598
-- 2025 55,313 · overdue 55,313
-- 2026 74,749 · overdue 30,839
-- (prior-calendar-year overdue, 2023-2025 = 187,129; total overdue = 217,968)
-- Direct aggregate behind the "86%" and "100% overdue" public displays.
-- audit-claim: prior-year-summary
SELECT
count(*) FILTER (
WHERE revalidation_due_date >= DATE '2023-01-01'
AND revalidation_due_date < DATE '2026-01-01'
AND revalidation_due_date < DATE '2026-06-15'
) AS prior_year_overdue,
count(*) FILTER (WHERE revalidation_due_date < DATE '2026-06-15') AS overdue,
round(
100.0 * count(*) FILTER (
WHERE revalidation_due_date >= DATE '2023-01-01'
AND revalidation_due_date < DATE '2026-01-01'
AND revalidation_due_date < DATE '2026-06-15'
) / count(*) FILTER (WHERE revalidation_due_date < DATE '2026-06-15')
) AS prior_year_pct_of_overdue,
round(
100.0 * count(*) FILTER (
WHERE revalidation_due_date >= DATE '2023-01-01'
AND revalidation_due_date < DATE '2026-01-01'
AND revalidation_due_date < DATE '2026-06-15'
) / count(*) FILTER (
WHERE revalidation_due_date >= DATE '2023-01-01'
AND revalidation_due_date < DATE '2026-01-01'
), 1
) AS prior_year_overdue_pct
FROM public.cms_revalidation_due_dates;
-- prior_year_overdue 187,129 · overdue 217,968 · share 86% · prior years 100% overdue
-- ============================================================================
-- (5) WHAT KIND of enrollment the backlog is — overdue cohort by enrollment
-- specialty, top 12. It is overwhelmingly ORGANIZATIONAL: 95.0% of overdue
-- enrollments carry an organization name (group practices, pharmacies,
-- agencies, suppliers) rather than an individual; Clinic/Group Practice
-- alone is 46.5% of the overdue cohort.
-- ============================================================================
-- audit-claim: specialty-vector
SELECT
enrollment_specialty,
count(*) FILTER (WHERE revalidation_due_date < DATE '2026-06-15') AS overdue,
round(100.0 * count(*) FILTER (WHERE revalidation_due_date < DATE '2026-06-15')
/ (SELECT count(*) FROM public.cms_revalidation_due_dates
WHERE revalidation_due_date < DATE '2026-06-15'), 1) AS pct_of_overdue
FROM public.cms_revalidation_due_dates
WHERE enrollment_specialty IS NOT NULL AND enrollment_specialty <> ''
GROUP BY enrollment_specialty
ORDER BY overdue DESC
LIMIT 12;
-- Clinic/Group Practice 101,391 46.5%
-- Pharmacy 31,152 14.3%
-- Mass Immunization (Roster Biller Only) 14,823 6.8%
-- Centralized Flu Biller 10,803 5.0%
-- Home Health Agency 4,271 2.0%
-- Physical/Occupational Therapy Group 3,986 1.8%
-- Ambulance Service Supplier 3,938 1.8%
-- Medical Supply Company 3,286 1.5%
-- Federally Qualified Health Center 2,830 1.3%
-- Physician - Podiatry 2,623 1.2%
-- Independent Clinical Laboratory 2,619 1.2%
-- Ambulatory Surgical Center 2,247 1.0%
-- (organization-named share of overdue = 207,177 of 217,968 = 95.0%)
-- Organization-name share of the overdue cohort, returned directly.
-- audit-claim: organization-name-share
SELECT
count(*) FILTER (
WHERE revalidation_due_date < DATE '2026-06-15'
) AS overdue,
count(*) FILTER (
WHERE revalidation_due_date < DATE '2026-06-15'
AND nullif(btrim(organization_name), '') IS NOT NULL
) AS organization_named,
round(
100.0 * count(*) FILTER (
WHERE revalidation_due_date < DATE '2026-06-15'
AND nullif(btrim(organization_name), '') IS NOT NULL
) / nullif(count(*) FILTER (
WHERE revalidation_due_date < DATE '2026-06-15'
), 0),
1
) AS organization_named_pct
FROM public.cms_revalidation_due_dates;
-- overdue 217,968 · organization_named 207,177 · organization_named_pct 95.0
-- The four organizational categories behind "roughly seven in ten."
-- audit-claim: top-four-concentration
WITH overdue AS (
SELECT enrollment_specialty
FROM public.cms_revalidation_due_dates
WHERE revalidation_due_date < DATE '2026-06-15'
)
SELECT
count(*) FILTER (WHERE enrollment_specialty = 'Clinic/Group Practice')
AS clinic,
count(*) FILTER (WHERE enrollment_specialty = 'Pharmacy') AS pharmacy,
count(*) FILTER (WHERE enrollment_specialty IN (
'Mass Immunization (Roster Biller Only)', 'Centralized Flu Biller'
)) AS roster_billing_combined,
count(*) FILTER (WHERE enrollment_specialty IN (
'Clinic/Group Practice', 'Pharmacy',
'Mass Immunization (Roster Biller Only)', 'Centralized Flu Biller'
)) AS top_four_combined,
round(100.0 * count(*) FILTER (WHERE enrollment_specialty IN (
'Clinic/Group Practice', 'Pharmacy',
'Mass Immunization (Roster Biller Only)', 'Centralized Flu Biller'
)) / count(*), 1) AS top_four_pct_of_overdue
FROM overdue;
-- clinic 101,391 · pharmacy 31,152 · roster billing 25,626
-- top four 158,169 of 217,968 = 72.6% ("roughly seven in ten")
-- ============================================================================
-- (6) WHERE the overdue enrollments are — top 10 states by overdue count, with
-- each state's own overdue share of its dated enrollments. The big states
-- lead on count (TX 27,670); several mid-size states show the highest
-- overdue shares (GA 93.3%, NC 92.1%, OH 91.6%, IL 91.5%).
-- ============================================================================
-- audit-claim: state-vector
SELECT
enrollment_state,
count(*) FILTER (WHERE revalidation_due_date IS NOT NULL) AS dated,
count(*) FILTER (WHERE revalidation_due_date < DATE '2026-06-15') AS overdue,
round(100.0 * count(*) FILTER (WHERE revalidation_due_date < DATE '2026-06-15')
/ NULLIF(count(*) FILTER (WHERE revalidation_due_date IS NOT NULL), 0), 1)
AS overdue_pct_of_dated
FROM public.cms_revalidation_due_dates
WHERE enrollment_state IS NOT NULL
GROUP BY enrollment_state
ORDER BY overdue DESC
LIMIT 10;
-- TX 32,860 dated · 27,670 overdue · 84.2% · CA 20,974 · 16,150 · 77.0%
-- NY 13,986 · 10,948 · 78.3% · FL 13,166 · 10,752 · 81.7%
-- IL 10,981 · 10,044 · 91.5% · NC 10,209 · 9,402 · 92.1%
-- OH 9,400 · 8,613 · 91.6% · GA 8,838 · 8,249 · 93.3%
-- MI 9,107 · 7,108 · 78.0% · PA 8,840 · 6,970 · 78.8%
Cite this study
Citation-ready for researchers and AI.
Fonteum Research Bureau (2026). Medicare Revalidation: The Backlog of Past-Due Deadlines. CMS PECOS, snapshot 2026-06-15. https://fonteum.com/research/medicare-revalidation-backlog-2026
Check the chain
The cited snapshot identifies the federal file. Where an attestation is present, its file hash can be re-derived; figures are not individually signed.
1
Snapshot
cms-pecos · 2026-06-152
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Not supplied3
Snapshot attestation
Inspect supplied artifactFigures are not individually signed · check it in Attest →
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Federal source citations
Fonteum LLC · June 15, 2026 · All figures trace to the frozen federal-data snapshot cited above.