The January 1, 2026, deadline for skilled nursing facilities (SNFs) to submit their mandatory off-cycle Medicare provider enrollment revalidation has been suspended indefinitely. In updated guidance issued December 9, 2025, the Centers for Medicare & Medicaid Services (CMS) clarified that there is currently no submission deadline for the SNF Attachment or the associated Form CMS-855A revalidation application.
This change supersedes the previous nationwide deadline and applies to all SNFs, including those that had pending initial enrollment, revalidation, reactivation, or change of ownership (CHOW) applications as of October 1, 2024, when the SNF Attachment requirement first took effect. SNFs may still submit revalidation applications at any time, but submission is no longer tied to a specific due date.
CMS explained that aside from the revised deadline language in Section (I)(C) and the addition of a new Section VIII, all other elements of the December 9 guidance remain unchanged. The reporting expectations associated with the SNF Attachment are still in effect. Facilities are still expected to collect and prepare detailed ownership, managerial, control, and related-party disclosures, consistent with previously issued requirements.
Key points drawn from the new guidance include:
- There is currently no deadline for submitting the SNF revalidation application or SNF Attachment, regardless of when a Medicare Administrative Contractor (MAC) originally issued a revalidation notice.
- The suspension also applies to SNFs with pending applications that were awaiting submission of the SNF Attachment; no due date applies at this time.
- Revalidation applications may still be submitted voluntarily as soon as they are ready.
- CMS will issue future updates when a new deadline is established.
The updated guidance also highlights concerns related to the Provider Enrollment, Chain and Ownership System (PECOS). CMS noted that some in-progress but not yet submitted SNF revalidation applications may have been removed from PECOS due to standard inactivity timeframes. While CMS is assessing whether deleted applications can be restored, recovery may not always be possible. Until the agency provides further direction, SNFs working on applications in PECOS are strongly encouraged to make at least one edit or addition every 120 days to prevent deletion for inactivity.
CMS provided timelines for automatic deletion based on an application’s status within PECOS:
- “New” or “Edit”: Deleted after 120 days of inactivity
- “Opened for Corrections”: Deleted if not submitted within 20 days
- “Rejected”: Deleted if not reopened or modified within 60 days; once reopened, deleted if not modified within 120 days
Although the submission deadline has been suspended, CMS continues to emphasize the importance of maintaining accurate enrollment information and preparing the required disclosures. Future updates will clarify the expected submission timeframe and address how CMS plans to handle any PECOS-related disruptions.
You can access the guidance here.
Compliance Perspective
Issue
With CMS’s indefinite suspension of the January 1, 2026, SNF revalidation deadline, facilities must remain attentive to ongoing requirements for ownership, managerial, and related-party disclosures under the SNF Attachment to Form CMS-855A. Although the formal deadline has been lifted, CMS continues to expect accurate and complete reporting, including careful management of in-progress PECOS applications, which may be deleted after periods of inactivity. Maintaining organized processes, monitoring PECOS activity, and ensuring staff understand the continuing expectations will help prevent disruptions once CMS establishes a future submission timeline.
Discussion Points
- Review policies and procedures to confirm they reflect the updated CMS guidance, including the indefinite suspension of the submission deadline and the new considerations related to PECOS application inactivity. Responsibilities for collecting, validating, and maintaining accurate ownership and ADP information should be clearly defined. Given the evolving nature of CMS’s guidance, facilities may find it useful to work with an external consultant to evaluate whether current policies and workflows support compliance and readiness for eventual submission once CMS announces a new due date.
- Provide targeted education to staff responsible for gathering, reviewing, or reporting ownership, management, and related-party information. Training should reinforce CMS definitions, documentation expectations, and PECOS requirements, with a focus on preventing application deletion due to inactivity. Med-Net Academy offers the course Long-Term Care Survey Process, which reviews entrance requirements, sample selection, survey phases, mandatory and triggered facility tasks, and the purpose and scope of the Survey Pathways. The course offers practical guidance that supports staff readiness for regulatory oversight and compliance activities.
- Conduct audits to verify that ownership, management, and ADP disclosures remain accurate and aligned with CMS requirements, and that PECOS applications in progress are being updated within the required timeframes to avoid removal. Audits may also help determine whether current processes identify information gaps or delays that could create challenges once CMS reestablishes a formal deadline. Engaging an external reviewer or consultant can help confirm alignment between internal records and expected disclosures, identify vulnerabilities, and strengthen ongoing compliance oversight.
*This news alert has been prepared by Med-Net Concepts, Inc. for informational purposes only and is not intended to provide legal advice.*