The Centers for Medicare & Medicaid Services (CMS) has extended the deadline for skilled nursing facilities (SNFs) to complete their mandatory revalidation submissions to August 1, 2025. This extension gives providers additional time to collect and report detailed information on ownership, managerial relationships, and related parties, as required under newly updated federal guidelines.
The revalidation process must now include expanded disclosures about individuals and entities that own, manage, or exert influence over SNF operations. Under the revised rules, SNFs must disclose:
- All owners and managers, including all Governing Body members, officers, directors, partners, and trustees. For SNFs structured as LLCs, all individual and organizational owners must be reported—regardless of ownership percentage.
- “Additional Disclosable Parties” (ADPs), which include any individual or organization that:
- Exercises financial or operational control over the SNF.
- Provides policies, management, or consulting services.
- Leases real property to the SNF or owns 5 percent or more of that property.
SNFs submitting enrollment, revalidation, reactivation, or ownership change applications on or after October 1, 2024, must use the revised Form CMS-855A, which includes the new SNF Attachment. While the original deadline to submit this information was May 1, 2025, the new August 1, 2025, deadline gives facilities a longer window to complete this complex reporting process.
The revised Form CMS-855A with the SNF Attachment can be found here.
Compliance Perspective
Issue
CMS has issued an update to its ownership disclosure requirements for all SNFs, effective April 9, 2025. These changes significantly expand the type and scope of information that must be reported, including detailed ownership structures and the identification of ADPs involved in financial or operational control. While facilities were originally required to comply by May 1, 2025, CMS has extended the deadline to August 1, 2025, allowing more time for providers to gather, verify, and submit the required data as part of their revalidation process. Failure to meet this revised deadline may result in enrollment delays or regulatory penalties. SNFs must now assess how to integrate these new reporting requirements into their operational and compliance frameworks to ensure timely and accurate submissions.
Discussion Points
- Update policies and procedures related to CMS enrollment and ownership disclosures to reflect the extended August 1, 2025, deadline and incorporate the revised requirements. Establish clear processes for gathering and verifying information on all owners, managers, and ADPs. Ensure that policies define who is responsible for submitting the revised Form CMS-855A with the SNF Attachment, and ensure staff are prepared to respond to CMS follow-ups and updates.
- Educate relevant staff on the new ownership reporting rules and the revised Form CMS-855A. Education should emphasize the expanded definitions of ownership and control, including how to identify ADPs.
- Conduct periodic audits to ensure the accuracy and completeness of reported ownership and ADP data. Ensure that supporting documentation aligns with what will be submitted to CMS and that appropriate controls are in place. Use audit findings to correct gaps, update records, and inform ongoing compliance efforts, particularly during enrollment, revalidation, or ownership transitions.
*This news alert has been prepared by Med-Net Concepts, Inc. for informational purposes only and is not intended to provide legal advice.*