Volume 25.09
Skilled nursing facility (“SNF”) providers enrolled in the Medicare program or dually enrolled in the Medicare/Medicaid programs must submit a mandatory off-cycle provider enrollment revalidation or risk having their enrollment suspended or revoked.
This special revalidation filing has been extended several times but is now due on or before January 1, 2026, and includes the submission of the SNF Attachment. The filing represents a substantial expansion to the information previously reported to CMS.
The purpose of the special filing is to allow CMS to collect updated and more detailed ownership, management, and related party information. The filing via the updated CMS-855A includes a new SNF Attachment. Required information includes:
- Each member of the SNF’s governing body,
- Each person or entity who is an officer, director, member, partner, trustee, or managing employee,
- Each person or entity who is an additional disclosable party (“ADP”) of the SNF, and
- The organization structure of each ADP of the SNF and a description of the relationship of each ADP to the facility and to one another.
An Additional Disclosable Party is any person or entity who:
- Exercised operational, financial, or managerial control over the SNF or a part thereof, or provides policies or procedures for any of the SNF’s operations, or provides financial or cash management services to the SNF,
- Leases or subleases real property to the SNF, or owns a whole or part interest equal to or exceeding five (5) percent of the total value of such real property, or
- Provides management or administrative services, management or clinical consulting services, or accounting or financial services to the facility.
There are substantial reporting requirements relating to persons/entities within the ADP.
SNF Governing Body – SNFs must now disclose all members of their governing board irrespective of their business type. This applies to for-profit and tax-exempt entities.
All LLC Owners – If the SNF is an LLC, all individual and organization owners of the LLC must now be reported regardless of their percentage of ownership.
Guidance for completion of the SNF Attachment is available here.
Facilities can submit the revalidation through the online Provider Enrollment, Chain and Ownership System (“PECOS”) or by a paper application.
MEDICARE CLAIMS PROCESSING DURING SHUTDOWN
The Centers for Medicare & Medicaid Services (CMS) has issued updated guidance on Medicare claims processing procedures during the federal government shutdown. In this revision, CMS clarifies that it will continue to process and pay held claims in a timely manner except for select claims for services impacted by the expired provisions.
CMS emphasized that no payments have been delayed to date, as federal law already requires all claims to be held for a minimum of fourteen days. The current claims hold remains consistent with that statutory requirement.