Texas Medicaid Tells Some Providers Saturday to Revalidate Early. No Extensions

On Saturday, October 31, TMHP will tell a set of Texas Medicaid providers that they have to revalidate sooner than their current due date. The notice goes out through PEMS, by letter and by email. Affected providers "are not eligible for any revalidation due date extensions," and HHSC "will disenroll them from Texas Medicaid and all associated state health care programs" if revalidation isn't completed by the due date PEMS shows.

Texas is answering the same April 23 CMS letter that sent South Carolina, Utah and Illinois after ABA providers by name. Texas works differently. It doesn't pick providers by type, so the question is whether your records put you in one of its four groups.

Who gets pulled forward

HHSC's revalidation strategy (revised June 2026) counts 7,507 providers as of June 4, 2026:

• Time-limited enrollments: 1,470. These are two-year enrollments, which OIG can recommend for, among other things, "anomalous billing patterns" or a pending licensing-board action.
• Risk manually elevated at revalidation: 207.
• Special review indicator: 9.
• Data discrepancies: 5,821, including revalidation dates in the past, dates more than five years out, and risk categories elevated in error.

ABA isn't on Texas's list of categorically high-risk provider types. The largest group is a records problem, not a conduct problem, and it's the one an ABA group is most likely to be in.

The rules once you're in

• New due dates fall between January 1, 2027 and June 5, 2028. The application window opens 180 days before the due date, with reminders at 180, 120, 90 and 45 days.
• "Submitting a revalidation application by the due date is not enough to avoid disenrollment." Revalidation counts only when PEMS shows "Closed-Enrolled."
• A disenrolled provider has to reenroll through PEMS.
• Organizations enrolled in Medicare too: TMHP's October 16 notice says owner, creditor and principal details (name, date of birth, SSN, EIN) must match between Medicare and Texas Medicaid. A PEMS maintenance change can take up to 30 business days, and you can't finish the revalidation application until it's done.

What to do

• Owner or credentialing lead, before Saturday: confirm the primary and secondary email addresses in PEMS go to a mailbox someone reads. STEPS users: the PEMS primary email must match the STEPS primary entity contact.
• After Saturday: open PEMS and read the "Revalidation Due Dates" column for the group enrollment and every enrolled rendering provider. A date that moved is your notice.
• If you bill Medicare as an organization: compare the owner and principal data in PECOS with PEMS this week. A mismatch costs up to 30 business days to fix.
• If a new date lands: calendar the 180-day opening and set your internal deadline at least 45 days before the due date, because the clock stops at "Closed-Enrolled," not at "submitted."