Volume 25.07
Skilled Nursing Facilities (“SNF”) that had an August 1, 2025, due date for submission of their CMS-855A revalidation has been pushed back to January 1, 2026.
The Form CMS-855A was revised to collect the SNF data addressed in this guidance. Beginning October 1, 2024, all SNFs that are initially enrolling, revalidating, reactivating, or undergoing a change of ownership (CHOW) under § 489.18 must submit this version of the Form CMS-855A (“09/24 version”) with the SNF attachment completed.
SNFs submitting a change of information (COI) must also use this version, though the SNF Attachment will not have to be completed in full at that time. For example, if the SNF is reporting a new managing employee, he/she will be disclosed on the Attachment (rather than in Section 6). However, the SNF does not need to report all its current owners, managers, related parties, etc. on the Attachment in its COI submission.
Revalidation Due Dates – Regardless of when the SNF received its notice of revalidation letter from its MAC, the revalidation application due date for ALL SNFs – irrespective of the state in which they are located — is January 1, 2026.
This January 1, 2026, 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 January 1, 2026.
Additional information is available at SNF Attachment Public Subreg Guidance, CMS Forms, and MLNC.
MEDICARE ADVANTAGE PLANS IN THE SPOTLIGHT
Healthcare providers of all types recognize the many issues that create problems surrounding coverage, payments, and patient care when dealing with Medicare Advantage Plans while attempting to provide the best for Medicare program beneficiaries. On July 22, 2025, a congressional hearing was held regarding Medicare Advantage.
The testimony given and congressional member comments focused on the many problems associated with the Medicare Advantage Program with many calling for an overhaul of the program. Specifically, the hearing focused on high rates of coverage denial, prior service authorizations, and inflated spending. Several legislators have proposed that Medicare Advantage Plans be required to pay providers at least as much as traditional Medicare pays.
All healthcare providers should take this opportunity to communicate with their representatives regarding the problems encountered when dealing with Medicare Advantage Plans. This is increasingly important as more Medicare program beneficiaries select coverage through Medicare Advantage Plans rather than traditional Medicare coverage. Many Medicare program beneficiaries are not aware of the implications that result from such a selection until they discover care has been denied or access to professionals is not as expected.