Polsinelli’s licensure, enrollment and certification team has extensive experience assisting clients in every stage of the licensure, enrollment and accreditation process. 

Polsinelli seamlessly partners with clients to effectively navigate complex state and federal regulations that significantly impact providers and suppliers. In addition to our experience, our team maintains strong relationships with state and federal regulators to provide in-depth guidance to clients on the process of obtaining initial licensure, changes of ownership, and other regulatory matters. Polsinelli regularly counsels clients on licensure, enrollment and certification issues across the lifespan of a health care organization. Our team handles issues across the entire spectrum of licensure, enrollment and certification, including: 

  • Certificate of need
  • Facility and professional state licensure
  • Medicare and Medicaid enrollment/certification
  • Survey response, including plans of correction
  • Accreditation — The Joint Commission, AAAHC and other national accreditation agencies
  • Changes of ownership and/or Changes of Information
  • Revocations/terminations
  • Revalidations

Polsinelli’s deep understanding of the statutes, regulations and the governmental authorities provides our clients with next-level knowledge and assistance on issues facing all facilities and organizations, including hospitals, skilled nursing facilities, pharmacies, ambulatory surgery centers, home health agencies, dialysis facilities, assisted living facilities, behavioral health facilities and other providers/suppliers.

Our team supports clients in a variety of ways:

  • Advising on day-to-day questions issues
  • Researching and advising on appropriate state licensure and enrollment categories
  • Guiding clients undergoing transactions or reorganizations on the regulatory notice and approval process for state licenses, Medicare and Medicaid enrollments, accreditations 
  • Successfully defending clients in CON, survey, revocation and termination proceedings 
  • Managing clients’ entire licensure and enrollment process, including creation of a licensure/enrollment database to store necessary backup documentation and to track timelines for revalidations, and expirations 
Related Capabilities
Publications
Not Just a Form: Eleventh Circuit Upholds CMS-855 Conviction, Expanding Medicare Enrollment Risk
Key Takeaways: The Eleventh Circuit recently upheld a surgeon’s conviction, prison sentence and forfeiture for false ownership disclosures on a CMS-855 Medicare enrollment form, reinforcing that inaccurate enrollment information can carry criminal consequences. The court confirmed that CMS-855 accuracy is not limited to initial enrollment but extends to every submission, including routine updates and revalidations. Providers and suppliers should implement robust CMS-855 verification and oversight controls across all submissions, with a focus on accuracy, consistency and accountability. The U.S. Court of Appeals for the Eleventh Circuit recently upheld an orthopedic surgeon’s conviction, nearly three-year prison sentence and forfeiture of $125,000 for making a false statement, in violation of 18 U.S.C. § 1035, on a Medicare enrollment application.1 This case underscores how false ownership disclosures by
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NYBOP May 2026 Deadline Is Fast Approaching: Do Your Pharmacy and Pharmacists Have the Right Licenses?
Key Takeaways: The New York State Board of Pharmacy (NYBOP) issued guidance in December 2025 requiring licensure both for pharmacies and for each individual pharmacist participating in shared pharmacy services arrangements when servicing New York patients. Nonresident pharmacy registration alone is no longer sufficient to satisfy shared services compliance. While this requirement becomes effective May 22, 2026, organizations should not delay taking action now. A proactive assessment and timely remediation of any licensure gaps will be critical to ensuring compliance moving forward. What Organizations Should Be Doing Now Evaluate your shared services model to identify where operations may be impacted; Confirm that all pharmacists supporting or involved in New York operations, including remote personnel, hold appropriate licensure and identify any gaps; Implement proactive compliance measures for any
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