CMS recently shared guidance for new skilled nursing facilities (SNFs) enrollment services. Like other providers and suppliers, skilled nursing facilities (SNFs) have long been required under Section 1124(a) of the Social Security Act (the Act) to disclose various ownership and managerial information. This data has previously been reported in Sections 5 and 6 of the Form CMS-855A and is outlined in Sections 10.6.7.1 and 10.6.7.2 of Chapter 10 of Pub. 100-08.
As of November 2024, SNF providers are now required to complete a separate Attachment for all ownership and control information. The new SNF Attachment of the Form CMS-855A therefore collects: (1) all SNF data previously disclosed in Sections 5 and 6 of the Form CMS-855A; and (2) additional information that Section 1124(c) requires. SNFs will no longer complete Sections 5 and 6 of the Form CMS-855A.
Since October 2024, Medicare Administrative Contractors (MAC) began to issue notices of “off-cycle revalidations,” requesting all SNFs to complete this updated CMS 855A and new attachment. Originally, these notices went out to one-third of SNFs that month, one-third in November, and one-third in December, with a 90-day requirement for submission from the date received. CMS has since revised the 90-day requirement.
Per CMS, regardless of when the SNF received its notice of revalidation letter from its MAC, i.e., October, November, or December, the revalidation application due date for ALL SNFs—irrespective of the state in which they are located—is May 1, 2025. This May 1, 2025 due date also applies to ALL SNFs that had a pending initial, revalidation, reactivation, or CHOW application as of October 1, 2024 and were requested to submit the SNF Attachment. The Attachment will not be due until May 1, 2025.
CMS emphasizes that the SNF is NOT required to wait until May 1, 2025 to submit its revalidation application or the SNF Attachment. After receiving the application submission request from the MAC, the SNF may submit said application any time before May 1, 2025. The May 1, 2025 due date applies notwithstanding any alternative due date listed in the original application submission request letter from the MAC.
To illustrate, suppose an SNF received a revalidation request from the MAC on October 10 with a listed due date of January 5, 2025. The SNF may disregard the January 5 due date because the May 1 date applies. Note that the MACs will NOT be reissuing application request letters with the new May 1, 2025 due date listed. Given the complexity of the information being requested, Forvis Mazars recommends that providers begin the process of gathering the required information well in advance of the May deadline to help ensure timely submissions.
Forvis Mazars stands ready to assist you with the submission of these revalidations. We understand the pressure to understand what is being requested, and to properly categorize, enter, and submit the revalidation in an accurate and timely manner. Our provider enrollment services are built around having experiences professionals to help you navigate these challenges as efficiently as possible, so you can focus on taking care of those you serve.
For more information, please reach out to an advisor at Forvis Mazars.