As we have noted before, Medicare’s focus on keeping bad actors out of the program has made the enrollment process fraught with peril. Minor errors in completing forms, misunderstanding who is a managing employee and who is a delegated official can stymie those who seek to update their information or now are required to under Medicare’s revalidation program. This means verifying all enrollment data. It is essentially filing a new application for enrollment. New regulations as a result of health reform have designated various types of providers in terms of the risk they pose to the program. DME and home health agencies are at the highest level of risk and new applicants are already subject to criminal background checks. IDTFs and physical therapists are a second level of risk.  Physician practices are at the lowest level of risk, but IDTFs owned by physicians are treated as IDTFs generally with no preferences or favorable presumptions because they are owned by physicians.  In “Medicare Enrollment: A Never Ending High Hurdles Race”, we explain further the practical implications of these processes.