What has to be tracked
Per clinician
Per clinician per payer
Per entity
Ongoing, monthly
The two highest-risk items
Build the system
1
Choose the tool realistically
The crossover is where the grid exceeds a few hundred rows. Past that, the volume exceeds what manual review reliably catches.
2
Structure the record
Six columns minimum: Item · Entity or person · Jurisdiction or payer · Due date · Lead time · Owner.Add status and last-verified date.
3
Set alerts on lead time, not due date
A due-date reminder leaves no time to renew. Use the lead times above.
4
Assign a named owner per row
Assign a named person, not a team such as “Operations.” Include a backup for anything whose lapse stops revenue.
5
Review monthly
Add “review the next 60 days of the compliance calendar” to the month-end close checklist.
6
Verify rather than assume
Quarterly, spot-check a sample against primary sources: the licensing board, PECOS, CAQH. The grid shows only what someone entered, which may not match the source.
7
Add every new hire and new entity on day one
Add them before they start, because items missed at setup tend to stay untracked.
Recovering from a lapse
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