The Centers for Medicare & Medicaid Services (CMS) has issued an update to its ownership reporting requirements for all skilled nursing facilities (SNFs). Effective April 9, 2025, the update requires SNFs to provide more detailed information about individuals and entities that own, manage, or influence facility operations.
Under the revised rules, SNFs must now disclose information about:
- 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 their ownership percentage.
- “Additional Disclosable Parties” (ADPs), which includes 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.
- “Additional Disclosable Parties” (ADPs), which includes any individual or organization that:
SNFs submitting enrollment, revalidation, reactivation, or ownership change applications on or after October 1, 2024, must include the SNF Attachment as part of the revised Form CMS-855A. Every SNF, regardless of location or when they were notified, must submit this information by May 1, 2025.
The revised Form CMS-855A with the SNF Attachment can be found here.
Compliance Perspective
Issue
The 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 “Additional Disclosable Parties” (ADPs) involved in financial or operational control. Facilities must comply by May 1, 2025, or risk enrollment delays or regulatory penalties. SNFs must now assess how to integrate these new requirements into their operational framework to ensure timely and accurate reporting.
Discussion Points
- Review and revise current policies and procedures related to CMS enrollment and ownership disclosures to incorporate the new requirements. Establish clear internal processes for gathering and verifying information on all owners, managers, and ADPs. Ensure that policies define who is responsible for preparing and submitting the SNF Attachment and outline procedures for responding to CMS inquiries or updates.
- Educate relevant staff on the updated Form CMS-855A and the expanded definitions of ownership and control. Education should focus on identifying ADPs and understanding the implications of inaccurate or incomplete disclosures.
- Conduct periodic audits to verify the accuracy and completeness of ownership and ADP disclosures. Ensure that documentation supports all reported information, and that roles and responsibilities are clearly defined. 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.*