In an effort to increase transparency, CMS is requiring all skilled nursing facility providers to complete an off-cycle provider enrollment revalidation. SNFs will be receiving notices from their respective Medicare Administrative Contractors (MAC) to collect additional data on ownerships, managerial, and related party information not previously required. Originally providers only had 90 days from the date of the letter to respond and submit the newly required information into the Medicare PECOS system to keep your enrollment status active. CMS has now extended the due date for all SNF revalidations and “pending as of October 1” to May 1, 2025, which was welcome news to providers.
Facilities need to be on the lookout for a letter from the MAC from October – December 2024 regarding this MANDATORY off-cycle revalidation.
Even though the deadline has been extended to May 1, 2025, do not delay starting to collect the data as it will be a very time-consuming process, particularly the identification of additional disclosable parties (ADPs) and then getting the required information from these third parties. Failure to submit the revalidation will put your Medicare certification at risk and you won’t be able to bill Medicare.
There is a new SNF-specific Appendix in CMS-855A Medicare Enrollment Application Institutional Providers that needs to be completed to collect additional data. Instructions can be found here.
Data required is as follows.
| · Direct ownership interest | · All governing body members |
| · Indirect ownership interest | · All owners of an LLC |
| · General and limited partnerships interests | · All trustees of the SNF if the SNF is a trust |
| · Mortgage or security interest | · All additional disclosable parties (ADPs) |
| · Corporate officers and directors | · Persons/Entities within the ADP |
| · Operational/managing control/Managing employee |
Beginning on October 1, 2024, all SNFs that are initially enrolling, revalidating, reactivating, or undergoing a change of ownership under §489.18 must submit the newly adopted version of Form 855A with the SNF attachment completed. If the status of any SNF transactions prior to 10/1 is “pending” in PECOS as of 10/1, the MAC will request the new Appendix be completed.
CMS has suggested providers seek counsel from an attorney to help interpret the new SNF reporting requirements regarding whether specific persons or entities within their organization should be disclosed. Parties that have specific questions beyond the guidance provided may e-mail SNFDisclosures@cms.hhs.gov.
