Medicare Revalidation Deadline for SNFsSubmit in PECOS by May 1, 2025

4/14/2025 - By Celia Nofsinger

NEW CMS RULES are requiring all SNF providers to report additional data on ownership, managerial, and related party information not previously required during the initial application and/or revalidation process. Importantly, this new requirement may dramatically expand the definition of who must be considered an additional disclosable related party. Providers must report this data as part of an off-cycle revalidation process on a revised Form CMS-855A.

IMPORTANTLY, Sections 5 & 6, which have historically been used for corporate and individual disclosures, have been supplanted by the new Attachment 1: Skilled Nursing Facility Disclosures.

The revised form and additional guidance can be found here: Become a Medicare Provider or Supplier | CMS.

All providers should have received revalidation notices from their MAC intermediary on a staggered basis in late 2023. Despite the dates found in those notices, all providers now have until May 1, 2025, to submit the required information in PECOS to keep their enrollment status active.

IT IS IMPORTANT THAT SNF PROVIDERS COMPLETE THIS MANDATORY REVALIDATION ACTION IN ORDER TO KEEP YOUR ENROLLMENT STATUS ACTIVE.

This mandatory off-cycle revalidation process will now utilize the newly added new Attachment 1: Skilled Nursing Facility Disclosures workpaper instead of Sections 5 & 6 of the enrollment form to complete this reporting.

Instructions on how to complete the new appendix section can be found here: SNF Attachment Public Subreg Guidance (cms.gov).

Mor information about the rulemaking behind the new mandatory reporting can be found here: Disclosures of Ownership and Additional Disclosable Parties Information for Skilled Nursing Facilities and Nursing Facilities; Definitions of Private Equity Companies and Real Estate Investment Trusts for Medicare Providers and Suppliers | CMS

HOW TO PREPARE

Review the new forms CMS-855A (CMS-855A Medicare Enrollment Application Institutional Providers) as well as the appendix instructions (SNF Attachment Public Subreg Guidance (cms.gov))
Confer with legal counsel to determine if there are potentially additional disclosable parties or other interpretations that apply to you as a SNF provider
Immediately start to gather the required information as this reporting can be quite complex
Start the reporting process in PECOS as soon as possible
Complete the reporting in PECOS on or before May 1, 2025

If you have questions about these new revalidation requirements, or any other question concerning compliance, reimbursement, or operations for your skilled nursing facility, Saltmarsh’s team of experienced healthcare consultants can help. You can find all of the services our team can provide to your facility on our website - Healthcare Consulting | Saltmarsh CPA.