CMS has officially extended the deadline for mandatory provider revalidation applications for skilled nursing facilities (SNFs) from May 1, 2025 to August 1, 2025. While this extension offers some breathing room, the scope of required information remains unchanged. Depending on your facility’s ownership and control structure, gathering and submitting the necessary documentation may still be a time-intensive process.
What’s New? Insights From Recent CMS Subregulatory Guidance
The most recent guidance (the tenth update since October 2024), dated May 9, 2025, includes clarification on ADPs and reporting of mortgage interest, among other items.
Who Is Not an Additional Disclosable Party (ADP)?
CMS has clarified that the following entities are not considered ADPs:
- Parties overseeing or providing technical assistance for SNF information systems
- Billing companies
- Ambulance companies
- Optometrists, podiatrists, prosthetists, or orthotists
- Hospices
- Vendors providing services such as dietary, housekeeping, laundry, paper shredding, trash or waste collection, or similar support services
Also Not Considered ADPs
Entities or individuals contracted to supply medical or non-medical equipment or items to a SNF or its staff, provided they do not perform ADP services as defined in Section 1124(c), are also not deemed ADPs. Examples include:
- Diagnostic/testing equipment providers
- Suppliers of oxygen or other durable medical equipment
- Vendors of beds, dressings, clothing, blankets, etc.
- Service providers who repair SNF equipment or items
- Providers of non-medical services to patients, e.g., hairdressers
CMS has also made modifications to Section D, which addresses mortgage and security interests and real property ownership. These changes aim to clarify reporting requirements but may still raise questions for some providers.
How Forvis Mazars Can Help
While these updates provide clarifications, some ambiguity remains. If you need assistance interpreting the requirements or completing your revalidation application, the professionals at Forvis Mazars are here to help you prepare for what’s next. Connect with us today to see how we can assist you with completing and submitting your application.