Skilled nursing facility (SNF) providers enrolled as Medicare or Medicare/Medicaid must submit a mandatory off-cycle provider enrollment revalidation by May 1, 2025. The Centers for Medicare and Medicaid Services (CMS) issued this mandatory process last September. While there have been multiple updates since the release, including extending the initial deadline, it is important for SNF providers to ensure completion of the revalidation process by May 1 or risk having enrollment suspended or revoked.
AHCA Resources
AHCA will host a member-only SNF Provider Revalidation “Office Hours” webinar on Friday, March 28, from 2 – 3 PM Eastern to provide an update and answer member questions. Advanced registration is required.
AHCA also offers a variety of SNF provider enrollment resources available on our Reimbursement website, including contact information, past webinars, feedback from CMS, and more.
CMS Resources
Additionally, providers can find detailed sub-regulatory guidance information on the new organizations and individual parties required to be reported on the CMS website .
CMS also offers a step-by-step screenshot of instructions on completing an application via the Medicare Provider Enrollment, Chain, and Ownership System (PECOS).
If you need support with PECOS after March 31, 2025, please contact the External User Services (EUS) Help Desk via email or call (866) 484-8049. Hours of operation are Monday through Friday, 7 AM – 7 PM Eastern.
Background
On November 17, 2023, CMS published a final rule in the Federal Register, “Medicare and Medicaid Programs; Disclosures of Ownership and Additional Disclosable Parties Information for Skilled Nursing Facilities and Nursing Facilities; Medicare Providers’ and Suppliers’ Disclosure of Private Equity Companies and Real Estate Investment Trusts.” This final rule implements parts of section 1124(c) of the Affordable Care Act, which requires SNFs to disclose detailed information about their ownership and management as well as additional data regarding: (1) other parties with which the SNF is associated; and (2) the ownership structures of these other parties.
Although some of the data required under section 1124(c) is already disclosed per section 1124(a), some of it is not and will therefore be newly reported. The new 20-page 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 CMS855A.
Initially, the CMS Medicare Administrative Contractors (MACs) sent notices to impacted providers between October and December 2024 with a requirement to submit the revalidation information within 90 days. However, CMS later announced an extension of the deadline for all providers through May 1, 2025. AHCA has requested additional guidance and relief to this new reporting requirement, but CMS has not announced any further extensions or revisions to the requirements or deadline.