NEW Off-Cycle Reporting Requirements for SNF Medicare Revalidations

10/1/2024 - By Cade Crawford

Beginning in October and continuing through December 2024, CMS is requiring action from all SNF providers to report additional data on ownership, managerial, and related party information not previously required during the 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 the off-cycle revalidation process on the revised Form CMS-855A. The revised form and additional guidance can be found here: Become a Medicare Provider or Supplier | CMS.

All providers will receive revalidation notices from their MAC intermediary, with one-third of SNFs receiving notices in October and the remaining two-thirds sometime in November or December. Providers will have 90 days from the date of the revalidation notice letter to submit the required information in PECOS to keep their enrollment status active.

This mandatory off-cycle revalidation process will now utilize a newly added SNF-specific appendix rather than sections 5 and 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).

HOW TO PREPARE

Ensure staff is on the lookout for the off-cycle revalidation notice from your MAC
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

AHCA will be hosting a webinar on this new reporting requirement soon so be sure to check their website regularly for registration and event information (AHCA Education: Upcoming Webinars (ahcancal.org)).

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.

About the Author | Cade Crawford

Cade is a senior consultant in the Healthcare Consulting practice of Saltmarsh, Cleaveland & Gund. His primary areas of focus include Medicare and Medicaid cost report preparation, data analysis of revenue and expenditures and reimbursement consulting for the firm’s post-acute healthcare clients. Prior to joining Saltmarsh, Cade was a legal assistant at a regional law firm where he provided bookkeeping and lien resolution assistance.