Can Medicare Revoke a Practice’s Enrollment Over Denied Claims Under the New 2027 Rule?
CMS removed the factors it once weighed before revoking providers for a pattern of noncompliant claims, made revocations retroactive and cut the
Read the articleEmail: info@webillhealth.com | Call: +1 (425) 818 9351
Business hours: Monday to Friday, 8am to 9pm EST
Montana Medicaid
Montana Medicaid, enrolled and paid
An active Montana Healthcare Programs enrollment, affiliations in place, and claims that are not denied for who ordered or attended.
Montana Healthcare Programs told providers in August 2026 that in its new claims system, expected in 2027, a facility's institutional claim will be denied when the attending provider lacks enrollment and a claim will be rejected when the rendering and billing providers are not affiliated. The Department of Public Health and Human Services posts the notices on its Claims Modernization page.
Ordering and referring providers
Must be enrolled even if they never bill Montana; a claim from an enrolled provider for services ordered by a provider without enrollment is denied. Medicaid Enrollment for Ordering, Referring, and Prescribing Providers, July 21, 2026
Attending providers
In the new claims system, expected in 2027, an enrolled facility's institutional claim is denied if the attending provider lacks enrollment. Medicaid Enrollment for Attending Providers, August 21, 2026
Affiliations
A claim without an affiliation between the rendering and billing provider is rejected in the new claims system; providers may start affiliating at any time. Affiliations Requirement in the Montana Healthcare Claims System, August 11, 2026
Claims transition
Soft launch December 14, 2026; go live listed for spring 2027 (confirm the current date); Gainwell Technologies takes over claims processing and EDI. Prepare for the Montana Healthcare Claims System Transition, September 30, 2026
Revalidation
Every five years; Montana set December 31, 2024 for overdue revalidations and warned of suspended payments, so confirm current status. Montana Healthcare Programs announcements history
Shared tax ID
A revalidation submitted for a sole proprietor under a shared tax ID is denied. Montana Medicaid provider enrollment
What we see in practice
45 to 90 days from submission to an active Medicaid ID.
In the official words
Claims submitted to the MTHCS without an affiliation between the rendering (treating) provider and the billing provider will be rejected.
Active enrollment is required even if the ORP provider does not bill Montana Healthcare Programs for their services.
Montana denies claims that name a provider who is not enrolled
Montana requires every ordering, referring and prescribing (ORP) provider to be enrolled, even one who never bills Montana. Medicaid Enrollment for Ordering, Referring, and Prescribing Providers, July 21, 2026 The department says that when an enrolled provider submits a claim for services ordered, referred or prescribed by a provider that has no enrollment, the enrolled provider's claim will be denied. Medicaid Enrollment for Ordering, Referring, and Prescribing Providers, July 21, 2026 Enrolling this way does not oblige the provider to accept members or submit claims. Medicaid Enrollment for Ordering, Referring, and Prescribing Providers, July 21, 2026
For attending providers the department points to Administrative Rules of Montana 37.85.402, which requires providers of services to be enrolled. Medicaid Enrollment for Attending Providers, August 21, 2026 In the new Montana Healthcare Claims System (MTHCS), expected to go live in 2027, an enrolled facility's institutional claim will be denied when an attending provider who is not enrolled provided or oversaw the services. Medicaid Enrollment for Attending Providers, August 21, 2026 Claims sent through a clearinghouse, on paper or through the claims module are all affected. Medicaid Enrollment for Attending Providers, August 21, 2026 Attending providers enroll under the Rendering Provider section of the enrollment page. Medicaid Enrollment for Attending Providers, August 21, 2026
The ordering notice adds that in the new claims system a claim is denied when a service needs an order, referral or prescription and the referring provider NPI is missing from the claim. Medicaid Enrollment for Ordering, Referring, and Prescribing Providers, July 21, 2026
Montana describes the ordering, referring and prescribing type as the right enrollment for people who only write orders and referrals. Montana Medicaid provider enrollment Federal rules set the same floor: ordering and referring professionals must be enrolled as participating providers. 42 CFR 455.410
Affiliations and trading partners change before the 2027 claims start
The 2027 rollout adds an affiliation requirement, and a claim submitted without an affiliation between the rendering provider and the billing provider will be rejected. Affiliations Requirement in the Montana Healthcare Claims System, August 11, 2026 Electronic claims are rejected at the Gainwell EDI gateway, with rejection response files returned to the submitter. Affiliations Requirement in the Montana Healthcare Claims System, August 11, 2026
An affiliation is a connection a provider, or its owners and managers, has with another entity or individual, and it is different from linking a provider. Affiliations Requirement in the Montana Healthcare Claims System, August 11, 2026 Providers and organizations may start affiliating at any time and are asked not to wait for go live. Affiliations Requirement in the Montana Healthcare Claims System, August 11, 2026
Gainwell Technologies will take over claims processing, payment and EDI functions. Prepare for the Montana Healthcare Claims System Transition, September 30, 2026 The September 30, 2026 letter lists a soft launch on December 14, 2026, when trading partners may register, begin testing and complete certification, and a go live expected in spring 2027, so confirm the current dates. Prepare for the Montana Healthcare Claims System Transition, September 30, 2026 Trading partners must register with Gainwell and obtain a new Trading Partner ID. Trading Partner Changes Coming in 2027, July 28, 2026 Provider training is expected to begin in November 2026. Prepare for the Montana Healthcare Claims System Transition, September 30, 2026
A provider that sends X12 files directly to Montana must register as a trading partner as well. Prepare for the Montana Healthcare Claims System Transition, September 30, 2026 A practice that sends claims through a billing agent or clearinghouse should make sure that partner is preparing, while a practice that enters claims directly through Direct Data Entry does not need to act on the trading partner change. Trading Partner Changes Coming in 2027, July 28, 2026
How enrollment works, step by step
- Choose the enrollment type. Individuals enroll as a sole proprietor, a rendering provider or an ordering, referring and prescribing provider, and organizations enroll as a group or a facility. Montana Medicaid provider enrollment
- Check the NPI registry first. Montana's 2025 ordering, referring and prescribing training starts with verifying your information in NPPES. Ordering, referring and prescribing training, September 4, 2025
- Give ownership information. Enrollments are denied when it is missing. Montana Medicaid provider enrollment
- Mail any paper documents with the Montana Provider Services Mail Cover Sheet. Montana Medicaid provider enrollment
- Set the effective date with care. In Montana's 2025 training for ordering, referring and prescribing enrollments, the effective date can go back 365 days from the application submission, and state approval is needed for any older date. Ordering, referring and prescribing training, September 4, 2025
- Wait for the welcome letter. It tells you the enrollment is active. Montana Medicaid provider enrollment
Montana says the enrollment type chosen can change processing time and the supporting documents required. Montana Medicaid provider enrollment Our working range for a Montana provider is 45 to 90 days from submission to an active Medicaid ID.
Where Montana enrollments lose money
Montana providers must verify and update their enrollment information every five years. Montana Healthcare Programs announcements history The department resumed revalidation after the COVID 19 public health emergency and sent notification letters, beginning in August 2023, to the address on file 90 days before each due date. Montana Healthcare Programs announcements history For overdue revalidations it set December 31, 2024 and said that failure to finish would result in suspended payments. That date has passed, so confirm current status with Montana Provider Relations. Montana Healthcare Programs announcements history Providers check status on the Provider Revalidation List. Montana Healthcare Programs announcements history
A sole proprietor enrollment cannot share a tax ID with an organization NPI or another individual NPI. Montana Medicaid provider enrollment A revalidation submitted for a sole proprietor under a shared tax ID will be denied, and the submitting party is told how to disenroll and enroll again. Montana Medicaid provider enrollment
A change in business ownership may require updated ownership and tax information before the new owner is active, and Montana asks providers to contact Provider Relations 60 days before the active date to avoid claim denials and duplicate submissions. Montana Medicaid provider enrollment For a purchased NPI, claims cannot be processed until the enrollment is complete. Montana Medicaid provider enrollment
Montana's October 7, 2026 notice says that when the new claims system launches in 2027 the timeframe for adjusting paid claims will be aligned to timely filing requirements. Claim Adjustment and Void Changes in the Montana Healthcare Claims System, October 7, 2026 In general, it says, clean claims must be submitted by the latest applicable deadline, which includes within 12 months of the date of service, the date retroactive eligibility was determined, or the date disability was determined. Claim Adjustment and Void Changes in the Montana Healthcare Claims System, October 7, 2026 An adjustment submitted after the applicable timely filing deadline will be denied, and repayment of the original claim will not be issued. Claim Adjustment and Void Changes in the Montana Healthcare Claims System, October 7, 2026
Check where you stand before you submit
WeBill Health runs Revenue Velocity Credentialing with 24/7 CAQH and PECOS lifecycle monitoring, so revalidation dates and affiliation gaps are caught before they become suspended claims. Every file gets Human Expert Review from a credentialing specialist before it goes to the Montana Department of Public Health and Human Services.
Sources
- Medicaid Enrollment for Ordering, Referring, and Prescribing Providers, July 21, 2026
- Medicaid Enrollment for Attending Providers, August 21, 2026
- Affiliations Requirement in the Montana Healthcare Claims System, August 11, 2026
- Prepare for the Montana Healthcare Claims System Transition, September 30, 2026
- Montana Healthcare Programs announcements history
- Montana Medicaid provider enrollment
- dphhs.mt.gov, ClaimAdjustmentandVoidChanges
- dphhs.mt.gov, TradingPartner
- dphhs.mt.gov, ClaimsModernization
- medicaidprovider.mt.gov, 2025ORPTrainingMaster
- ecfr.gov, title 42.xml
- ecfr.gov, title 42.xml
Revenue Velocity Credentialing
WeBill Health manages the full payer enrollment lifecycle, so your revenue cycle starts the moment your practice does.
Up to 40%
less payer enrollment lag against the industry baseline
24/7
CAQH and PECOS lifecycle monitoring
Review your enrollment status with us
The Revenue Defense Audit is a free, forensic review of your claims and A/R by the team that would work your account, including providers seeing patients under a payer that cannot pay them yet.
Want a quick read first? Check my Revenue Defense Score for the credentialing and denial exposure in your specialty.
Worth reading
View all articles
How Much Is Your Credentialing Delay Actually Costing You?
A one day delay in credentialing a new provider costs a medical group roughly 10,122 dollars in lost billing capacity, according to
Read the articleThe Denial Root Cause Playbook
Find the three denial patterns costing you most, trace each to its cause with the CARC code map, and close it at source. Appeal deadline table, checklist and worksheet included.