Concurrent with the Covid-19 Public Health Emergency (“PHE”), the Arizona Health Care Cost Containment System (“AHCCCS”) modified requirements related to member enrollment and provider revalidation. Following the Consolidated Appropriations Act of December 2022, Medicaid is decreasing specific additional funding made available during the PHE. As a result, AHCCCS has returned to the regular renewal process for members and providers.[1]
AHCCCS will begin to disenroll ineligible members on April 1, 2023. The return to normal will also impact providers as AHCCCS is phasing out many provider enrollment flexibilities adopted during the PHE (for example, streamlining enrollment requirements for out of state providers).[2] AHCCCS is currently in the process of contacting providers for revalidation using the contact information on file for the provider.[3] It is therefore critical for providers to ensure their contact information is current and to proactively monitor for AHCCCS communications.
Generally, AHCCCS providers must revalidate every four years, or as requested by AHCCCS.[4] Revalidation requirements vary by provider type and may include, but are not limited to: (i) requests for the same screening and disclosures captured during initial enrollment; (ii) an enrollment fee; (iii) a site visit; and/or (iv) fingerprint criminal background checks.
Revalidation may be completed in the AHCCCS Provider Enrollment Portal (“APEP”). Providers who fail to revalidate could face loss of access to the AHCCCS Online Portal, loss of billing privileges, and/or termination of their Provider Participation Agreement.[5] Providers with questions or those who are no longer participating as a Medicaid provider are encouraged to contact AHCCCS at APEPTrainingQuestions@azahcccs.gov.
Providers are advised to keep watch for any communication from AHCCCS relating to revalidation and confirm AHCCCS coverage with patients. Providers should expect potential further changes to AHCCCS flexibilities at the end of the PHE. A list of AHCCCS requested flexibilities and their expiration dates is available here. Unless extended by the U.S. Secretary of the Department of Health and Human Services, the PHE is scheduled to expire on May 11, 2023.[6]
[1] Arizona Health Care Cost Containment System, Preparing for the End of COVID-19: Return to Regular Renewals (2023). Available here.
[2] Arizona Health Care Cost Containment System, Status of AHCCCS Emergency Authority Requests (for the federally declared COVID-19 emergency) (2023). Available here.
[3] Arizona Health Care Cost Containment System, Provider Revalidation (2023). Available here.
[4] Id.
[5] Id.
[6] U.S. Department of Health & Human Services, Renewal of Determination that a Public Health Emergency Exists (Feb. 9, 2023), available here; supra note 2.
