Track licenses, revalidations, and expirables

An MSO-PC group tracks hundreds of dated obligations across entities, clinicians, and payers. A single lapse — a license, a CAQH attestation, a Medicare revalidation — stops revenue. This guide builds the tracking system.

What has to be tracked

Per clinician

Item	Cadence	Lead time
State professional license	1–3 years, per state	60 days
DEA registration	3 years	60 days
State controlled substance registration	Varies	60 days
Board certification	Per board	90 days
CAQH attestation	~120 days	14 days
Malpractice coverage	Annual	60 days
CME	Per board	90 days
BLS/ACLS where applicable	2 years	30 days
Immunizations / TB where required	Annual	30 days

Per clinician per payer

Item	Cadence	Lead time
Commercial recredentialing	~3 years	90 days
Medicaid MCO recredentialing	~3 years	90 days

Per entity

Item	Cadence	Lead time
Medicare revalidation	5 years (3 for DMEPOS)	90 days
Medicaid revalidation	At least 5 years, state-specific	90 days
Payer contract renewal / rate review	Annual	90 days
State annual report	Annual, per state	60 days
Franchise tax	Annual, per state	30 days
Registered agent renewal	Annual	30 days
Business licenses	Varies	30 days
Facility licenses where applicable	Varies	60 days

Ongoing, monthly

Check
OIG LEIE exclusion screening, all staff and contractors
SAM.gov debarment screening
State Medicaid exclusion lists
License status spot-check

The two highest-risk items

CAQH attestation expires roughly every 120 days and, when it lapses, makes profiles invisible to payers mid-credentialing. It is the highest-frequency item on this page and the one most often missed.Medicare revalidation notices go to the correspondence address in PECOS. If nobody monitors that address, the first you’ll hear is when billing privileges are deactivated and claims stop. Confirm the address is monitored, and check your due date directly in the Medicare Revalidation Lookup Tool rather than waiting for a notice.

Build the system

Choose the tool honestly

Scale	Tool
1–5 clinicians, 1 entity	Spreadsheet plus calendar reminders
5–20 clinicians, 1–3 entities	Spreadsheet plus a task system, or entry-level credentialing software
20+ clinicians, or 3+ entities	Credentialing software

The crossover is where the grid exceeds a few hundred rows. Past that, manual tracking fails not because anyone is careless but because the volume exceeds what review catches.

Structure the record

Six columns minimum: Item · Entity or person · Jurisdiction or payer · Due date · Lead time · Owner.Plus status and last-verified date.

Set alerts on lead time, not due date

A reminder on the due date is a reminder you’re late. Use the lead times above.

Assign a named owner per row

“Operations” is not an owner. A person is. Include a backup for anything whose lapse stops revenue.

Review monthly

Add “review the next 60 days of the compliance calendar” to the month-end close checklist.

Verify rather than assume

Quarterly, spot-check a sample against primary sources — the licensing board, PECOS, CAQH. Your grid records what someone entered; the source records what is true.

Add every new hire and new entity on day one

Before they start, not after. The setup step is where drift begins.

Recovering from a lapse

Lapse	Immediate action
License expired	Stop the clinician from practicing. Renew immediately. Assess claims billed during the lapse: they may be unbillable and may need to be refunded.
CAQH attestation lapsed	Re-attest immediately; notify payers with pending applications
Medicare revalidation missed	Submit immediately; deactivation is possible and reactivation may not be fully retroactive
Malpractice lapsed	Stop clinical work until reinstated; notify payers if coverage falls below their minimums
DEA expired	Stop prescribing controlled substances immediately
Recredentialing missed	Contact the payer; you may be terminated from the network
Annual report missed	File immediately with any late fee, before administrative dissolution

A lapsed license means claims for services during the lapse may be unbillable, and services already paid may be subject to refund. Discovering an overpayment starts the 60-day report-and-return clock for Medicare and Medicaid. See Report and return overpayments.

Verify it worked

Every item above is in the tracking system
Alerts set on lead time, not due date
Named owner and backup per row
Monthly review is part of the close checklist
Quarterly primary-source spot-check running
PECOS correspondence address monitored by a named person
Monthly exclusion screening documented
New hires and new entities added at onboarding

Common failure modes

Failure	Consequence
Spreadsheet outgrown but not replaced	Rows silently missed
Alerts on the due date	Always late
No named owner	Nobody acts
PECOS address unmonitored	Deactivated billing privileges
Exclusion screening at hire only	Post-hire exclusion undetected
New entity not added at setup	Its obligations tracked by nobody
Grid never verified against primary sources	Records what was entered, not what’s true

Formation & Corporate

Agreements

Credentialing & Payer Enrollment

Billing Operations

Patient Payments & Refunds

Banking & Finance

Compliance Tasks

Track licenses, revalidations, and expirables

What has to be tracked

Per clinician

Per clinician per payer

Per entity

Ongoing, monthly

The two highest-risk items

Build the system

Recovering from a lapse

Verify it worked

Common failure modes

​What has to be tracked

​Per clinician

​Per clinician per payer

​Per entity

​Ongoing, monthly

​The two highest-risk items

​Build the system

​Recovering from a lapse

​Verify it worked

​Common failure modes

What has to be tracked

Per clinician

Per clinician per payer

Per entity

Ongoing, monthly

The two highest-risk items

Build the system

Recovering from a lapse

Verify it worked

Common failure modes