CMS Extends Deadline for All Mandatory Off-Cycle SNF Provider Enrollment Revalidations
Earlier this week, The Centers for Medicare and Medicaid Services (CMS) extended the due date to May 1, 2025, to submit the new Form CMS-855A SNF Disclosures Attachment 1 nationwide for all SNF revalidations and for all “pending as of October 1” applications. This replaces the original 90-day period that was required to submit information (with exception of states impacted by the recent hurricanes) within receiving notice from a respective Medicare Administrative Contractor (MAC) between October and December 2024.
This positive development comes after AHCA/NCAL expressed strong concerns with the 90-day deadline to HHS and CMS in a letter last month.
Specifically, the new CMS disclosable parties reporting submission timeline guidance states:
- Due Dates for All SNFs: Regardless of when the SNF received its notice of revalidation letter from its MAC (i.e., October, November, or December), the revalidation application due date for ALL SNFs – irrespective of the state in which they are located — is May 1, 2025. This May 1, 2025, due date also applies to ALL SNFs that – as explained in Section (I)(B) above – had a pending initial, revalidation, reactivation, or CHOW application as of October 1, 2024, and were requested to submit the SNF Attachment. The Attachment will not be due until May 1, 2025. The previous restriction of the May 1, 2025, date to SNFs in Florida, Georgia, South Carolina, North Carolina, and Tennessee no longer applies.
This is one of two updates posted by CMS over the past week to its sub regulatory guidance related to this revalidation process. It also contains new technical guidance, clarifications, and answers to FAQs to assist providers in submitting the required information, including clarification on:
- The number of organizational charts that must be submitted (see Section (VI)(C))
- Clinical consulting services and policies/procedures (see new Section VI(G)))
- Sections (III)(E)(i) and (ii) that both categories of bulleted parties must be reported.
Additional Resources
AHCA/NCAL will continue to provide and update resources for members during this timeframe, including on our website, as well as assisting members through our Member Provider Enrollment Revalidation Helpdesk. AHCA/NCAL will also host four Office Hours webinars on November 15, December 6, January 10, and January 31.
Please contact 855Revalidation@ahca.org with any questions.