Member Article

To implement its November 2023 final rule on ownership transparency for skilled nursing facilities (“SNFs”), the Centers for Medicare and Medicaid Services (“CMS”) has updated its Medicare enrollment application for institutional providers (“CMS-855A”). Initially intended to obtain information about private equity and real estate investment trusts to assess the impact of ownership on quality of care, the final rule now requires several  additional categories of information that were not previously required to be reported.

The revised CMS-855A, which became effective October 1, 2024, features a new ‘Attachment 1: Skilled Nursing Facility Disclosure’ (“Attachment 1”).  In addition to expanded disclosures related to ownership, SNFs are required to report information related to certain Additional Disclosable Parties (“ADPs”) on Attachment 1.  ADPs are broadly defined and reporting includes advisors, consultants and vendors whose services impact operational, financial or managerial control of the SNF.

In October, CMS initiated off-cycle revalidations on a rolling basis for all SNFs nationwide.  Each SNF will receive a notice of revalidation letter from its Medicare Administrative Contractor before year end. The revalidations must be completed on the revised CMS-855A. Due to the expansive nature of the newly required information on Attachment 1, CMS has extended the deadline for completion of revalidation applications to May 1, 2025, regardless of the date that a SNF receives its notice of revalidation letter.[1]

If you have questions about revalidation or the new CMS-855A form, please contact your Dinsmore attorney.

[1] Centers for Medicare and Medicaid Services, Guidance for SNF Attachment on Form CMS-855A, (November 26, 2024), available at https://www.cms.gov/files/document/guidance-snf-attachment-855a.pdf.