SNFs must complete mandatory off-cycle revalidations to keep Medicare enrollment current and accurate or else risk losing billing privileges.
Beginning in October, skilled nursing facilities (SNFs) should watch for a revalidation notice from their respective Medicare Administrative Contractor (MAC). This is a mandatory, off-cycle revalidation requirement, and an outgrowth of the new reporting requirements the Centers for Medicare and Medicaid Services (CMS) finalized in 2023 related to ownership, management, and related-party transactions.
The agency continues its focus towards greater transparency and accountability related to skilled nursing facility (SNF) ownership, management, and related-party information. In November 2023, the agency finalized changes and additional requirements, including related to private equity companies and real estate investment trusts.
CMS has announced the SNF mandatory enrollment off-cycle revalidation process where all SNFs are required to revalidate their Medicare enrollment information outside of the regular validation cycle. This process confirms the information on file with Medicare is accurate and up to date.
Key points about SNF mandatory enrollment off-cycle revalidation
- Purpose — To maintain accurate and current enrollment information with Medicare.
- Timing — One-third of SNFs will get notices from their MAC in October and the remaining two-thirds will get notices in November or December. Providers have 90 days from the date of the letter to submit the new information.
- Requirements — Each SNF will need to submit information in a new appendix on the revised Form CMS-855A (September 2024 version). The appendix is 20 pages to be completed instead of Sections 5 and 6 all other providers complete. Providers should submit their data into the Medicare Provider Enrollment, Chain, and Ownership System (PECOS) system.
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Failure to submit your required information timely may subject you to having your provider enrollment status inactivated and billing privileges terminated. A new provider application will need to be submitted to reactivate the provider. |
CMS will also require the new appendix (referred to as “Attachment” in the 855A form) for all provider enrollment transactions effective October 1, 2024. These transactions include initial enrollment, revalidations, reactivations, and change of ownerships. If any of these transactions are “pending” prior to October 1, they will need to be updated to include the new appendix.
How we can help
As you prepare for this off-cycle revalidation:
- Familiarize yourself with the new 855A reporting requirements
- Watch for the MAC notice
- Determine who internally is responsible for facilitating and completing the report
- Begin compiling any new information necessary for reporting
- Respond in a timely manner (within 90 days)
- Reach out to CLA for assistance
Navigating the enrollment and revalidation process is challenging and complex. CLA has the experience and resources to assist you in preparing the Form 855A. We also recommend working with your legal counsel to review any data prior to submission.
Additional resources
- For background on this CMS regulation, read our earlier article
- CMS enrollment forms
- SNF attachment guidance
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