At an October 17 Skilled Nursing Facilities (SNF) Open Door Forum, the Centers for Medicare and Medicaid Services (CMS) addressed many provider questions on new requirements for reporting of nursing home ownership, management, and related parties data.

CMS recently updated guidance on completing this reporting via Form 855A and announced that the Medicare Administrative Contractors (MAC) will be conducting off-cycle revalidations for all nursing homes October – December to implement these new reporting requirements.

During the SNF Open Door Forum, CMS emphasized that the guidance has been updated since its release and more updates are planned as questions and need for clarification emerge. In general, off-cycle revalidations are due within 90 days of notice from the MAC. For nursing homes that were pending revalidation or Change of Ownership (CHOW) when the updated form was released, the SNF attachment is required within 60 days of request from the MAC.

Due to the emergency declarations related to Hurricanes Helene and Milton, providers in Florida, Georgia, South Carolina, North Carolina, and Tennessee are automatically granted until May 1, 2025 to submit revalidations and SNF attachments for pending revalidations and CHOWs. Fees and site visit requirements will also be waived for providers in these states.

CMS has established a new HelpDesk email for questions related to the updated form and guidance. The agency urges providers to first check updated guidance before emailing  SNFDisclosures@cms.hhs.gov with questions. For answers to questions about the off-cycle revalidation process and pending revalidations and CHOWs, contact the Medicare Administrative Contractor.