CMS Requires Mandatory Revalidation in SNFs

October 15, 2024-- In November 2023, CMS finalized a regulation requiring Skilled Nursing Facilities (SNFs) to disclose ownership information. On September 19, 2024, CMS announced that mandatory off-cycle SNF revalidations will start on October 1, 2024, and run through December 2024. CMS also finalized their longer Provider Enrollment Form CMS-855-A and added a new SNF Appendix to report information about Additional Disclosable Parties (ADP). 

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What to expect:

• This change will apply to all SNFs regardless of size or ownership
• The revalidation notices will be distributed evenly over the three-month period, with a third of SNFs being contact by their MAC each month
• SNFs will have 90 days to respond to the letter and submit all required information
• The new form referenced above must be used for all provider enrollment transactions effective October 1, 2024, including:
  • Initial Enrollment
  • Revalidations 
  • Reactivations 
  • Change of Ownership (CHOW) 
• SNF providers do not have to report in Sections 5 and 6 of the enrollment form. 
• In addition to requiring information about the SNF’s ownership and management, the form requires information from other parties with which the SNF is associated, and the ownership structures of these other parties. 

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How to prepare:

• Review the new Enrollment Form CMS-855-A
• CMS recommended that providers utilize legal counsel to interpret the new reporting requirements
• Begin compiling the required information for reporting
• Work with vendors and partners to determine how they fit into the definitions of Additional Disclosable Party (ADP) and what information they will need to provide
• Respond to the letter within 90 days

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Powerback will work proactively with our customers to ensure that all information is provided in a timely manner. 

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