The Centers for Medicare & Medicaid Services (CMS) recently enacted a new "stay of enrollment" status that permits CMS to discipline providers and suppliers for minor violations of provider enrollment requirements that do not justify the more punitive implications of a deactivation or revocation.. Akerman Healthcare Practice Chair Robert Slavkin and Associate Danielle Gordet, recently discussed the new status with PlanBNews.

CMS has discretion to impose a stay, based on the facts and circumstances of each case. "It’s possible that the same instances that could trigger a stay could also trigger a revocation, as CMS has discretion to decide which to impose," they told the publication. "For example, CMS may impose a deactivation or revocation (if grounds exist for either) without first applying a stay."

Slavkin and Gordet also noted that if the non-compliance persists when the stay ends, CMS could impose a deactivation or revocation.