The Centers for Medicare & Medicaid Services (CMS) has further extended the deadline for skilled nursing facilities (SNFs) to submit their revalidation applications and the new SNF Attachment. All SNFs—regardless of location or the timing of their initial revalidation request—now have until January 1, 2026, to complete this process.
This latest extension applies to all SNFs with pending initial enrollment, revalidation, reactivation, or change of ownership (CHOW) applications as of October 1, 2024, and who were asked to complete the SNF Attachment. CMS has emphasized that although the new due date is January 1, 2026, facilities may submit their applications and attachments at any time after receiving a request from their Medicare Administrative Contractor (MAC).
Key reminders under the updated guidance:
- Uniform Due Date: The January 1, 2026, deadline supersedes any alternative due date listed in the original revalidation letter from the MAC. For example, a facility that received a letter with a listed deadline of January 5, 2025, should instead follow the extended January 1, 2026, deadline.
- No Need to Wait: SNFs are encouraged not to delay submission. While January 1, 2026, is the final due date, facilities may submit their revalidation application and SNF Attachment as soon as they receive their request letter.
- Processing of Pending Applications: CMS will not delay review of applications already in process. For example, if a CHOW application was submitted before October 1, 2024, and the MAC has requested the SNF Attachment, the application will continue to be reviewed and sent to the State Agency as needed. However, final CMS approval will not occur until the SNF Attachment is received and processed.
As previously outlined, the SNF Attachment requires disclosure of detailed ownership and control information, including:
- All owners and managers (including governing body members, officers, directors, partners, and trustees).
- All individual and organizational owners of LLCs, regardless of ownership percentage.
- “Additional Disclosable Parties” (ADPs), such as individuals or organizations that:
- Exercise operational or financial control over the facility,
- Provide management, policy, or consulting services, or
- Lease property to the SNF or own 5% or more of that property.
The revised Form CMS-855A, which now includes the SNF Attachment, must be used for all applications submitted on or after October 1, 2024.
More information, including detailed instructions for completing the SNF Attachment, is available here in CMS’s updated guidance.
Compliance Perspective
Issue
CMS has issued updated guidance regarding ownership and control disclosures for SNFs, further extending the compliance deadline for the revised Form CMS-855A and SNF Attachment to January 1, 2026. This uniform due date applies to all SNFs, regardless of when their MAC issued a revalidation request. The extension also applies to SNFs with pending enrollment, reactivation, revalidation, or CHOW applications as of October 1, 2024. While the extension provides additional time for SNFs to compile complex ownership and control data, including details on ADPs, CMS has emphasized that applications may still be submitted at any time prior to the new deadline. SNFs must continue adapting internal processes to align with these revised expectations to avoid delays in enrollment approvals and to ensure compliance.
Discussion Points
- Update policies and procedures related to CMS enrollment and ownership disclosures to reflect the January 1, 2026, deadline and to ensure accurate identification and reporting of all owners, managers, and ADPs. Include guidance on how to treat revalidation letters that reference earlier deadlines, and outline steps for timely submission using the revised Form CMS-855A with the SNF Attachment. Facilities may also consider working with a compliance consultant to ensure policies align with updated regulatory expectations and CMS guidance.
- Train relevant staff on the extended deadline and the associated guidance from CMS. Emphasize the ongoing obligation to identify individuals or entities that meet the expanded ADP criteria, and clarify that facilities can submit the required documentation before the January 1, 2026, deadline. As part of ongoing preparation for regulatory oversight, facilities may also consider supplemental training such as the Long Term Care Survey Process course available through Med-Net Academy.
- Audit to validate the accuracy of ownership, management, and ADP information included in pending or upcoming applications. Verify that all data aligns with internal documentation and CMS requirements, particularly for facilities with applications submitted or pending as of October 1, 2024. An external review—such as a focused audit or mock assessment—can help identify potential gaps and strengthen submission readiness. Use audit outcomes to inform corrections and enhance oversight ahead of final CMS approval.
*This news alert has been prepared by Med-Net Concepts, Inc. for informational purposes only and is not intended to provide legal advice.*