The deadline for skilled nursing facilities (SNFs) to submit their mandatory off-cycle Medicare provider enrollment revalidation remains suspended indefinitely, and for the time being, there is no submission deadline. In guidance issued February 24, 2026, the Centers for Medicare & Medicaid Services (CMS) clarified that SNFs required to submit the SNF Attachment for pending applications are exempt from the off-cycle revalidation process and will not be asked to submit the Attachment twice. SNFs that have not yet submitted their revalidation applications, or whose applications were rejected and not resubmitted, are still required to submit them eventually but may wait until CMS announces a new due date. Immediate resubmission is permitted and encouraged but is not required until a new deadline is established.
SNFs must continue to respond promptly to any clarifying or missing data requests from their Medicare Administrative Contractor (MAC). Pending applications are not exempt from MAC timelines, and MACs will continue to process incoming and pending applications and issue determination letters.
CMS also emphasizes the importance of maintaining activity in the Provider Enrollment, Chain and Ownership System (PECOS). Unsubmitted applications may be removed due to inactivity, so SNFs are strongly encouraged to make at least one edit or addition every 120 days to prevent deletion. CMS is reviewing whether deleted applications can be recovered; however, some may not be retrievable.
All SNFs must use the revised 09/24 version of Form CMS-855A with the SNF Attachment for initial enrollment, revalidation, reactivation, and CHOW applications. Change of information submissions require only partial completion of the Attachment, reporting only the new information (for example, a new managing employee) rather than the full current ownership or related-party data. Pending applications submitted using the previous 09/23 version may also require submission of the SNF Attachment, coordinated to avoid duplicate off-cycle revalidation.
CMS continues to stress that all prior disclosure requirements remain in effect, including information on owners, managing employees, related parties, medical directors, and administrators. SNFs should carefully prepare and submit all required information to ensure compliance with federal enrollment rules.
Until CMS announces a new deadline, SNFs should focus on maintaining PECOS activity, ensuring accuracy of information, and preparing all required disclosures.
Access the updated guidance here.
Compliance Perspective
Issue
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 oversight of in-progress PECOS applications, which may be deleted after periods of inactivity. Maintaining organized processes, monitoring PECOS activity, and ensuring staff understand continuing expectations will help prevent disruptions once CMS establishes a 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 management information should be clearly defined. Facilities may find it beneficial to work with their consultant to evaluate whether current policies and workflows support compliance and readiness for 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 related-party 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 a 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.*