Skilled nursing facility (SNF) providers enrolled in Medicare, or Medicare and Medicaid, must submit their mandatory off-cycle provider enrollment revalidation by January 1, 2026, or risk having their enrollment suspended or revoked. The Centers for Medicare & Medicaid Services (CMS) extended this deadline from August 1, 2025, to provide relief from the extensive new reporting requirements associated with the SNF Attachment.
All SNFs—regardless of location or the timing of their initial revalidation request—are required to meet the January 1, 2026, deadline. This includes facilities with pending initial enrollment, revalidation, reactivation, or change of ownership (CHOW) applications as of October 1, 2024, when the SNF Attachment requirement took effect. Facilities may submit their revalidation applications and attachments at any time after receiving a request from their Medicare Administrative Contractor (MAC).
Key reminders:
- The January 1, 2026, deadline replaces any earlier deadline listed in a facility’s original MAC revalidation letter.
- Facilities do not need to wait to submit; revalidation materials may be submitted as soon as the MAC request is received.
- CMS continues to process applications already in progress, but no application will receive final approval until the SNF Attachment is submitted and processed.
As previously outlined, the SNF Attachment requires detailed disclosures regarding ownership and control, including:
- All owners and managing individuals (governing body members, officers, directors, partners, trustees).
- All individual and organizational owners of LLCs, regardless of percentage.
- “Additional Disclosable Parties” (ADPs), such as individuals or organizations that exercise operational or financial control, provide management, policy, or consulting services, or lease property to the SNF or own 5 percent or more of that property.
The revised Form CMS-855A, which 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.
Compliance Perspective
Issue
As the revised deadline draws closer, SNFs must ensure full compliance with CMS’s updated ownership and control disclosure requirements outlined in Form CMS-855A and the SNF Attachment. These requirements apply broadly to all SNFs, including those with pending enrollment, revalidation, reactivation, or CHOW applications, and require thorough and accurate reporting of ownership, management, and ADP information. To meet these expectations, facilities should keep their processes organized, ensure staff know what information is needed, and check that all required disclosures are complete and up to date.
Discussion Points
- Review and update policies and procedures to ensure they reflect current CMS expectations for enrollment, ownership disclosures, and timely submission requirements. Clarify responsibilities for collecting, validating, and maintaining accurate information, and address how the facility will manage regulatory updates that impact reporting or documentation processes. Facilities may also consider collaborating with an external consultant to evaluate whether policies and procedures are aligned with CMS requirements and support overall operational readiness.
- Provide targeted education to staff involved in collecting, reviewing, or reporting ownership and control information. Training should reinforce CMS definitions for owners, managers, and ADPs, clarify the documentation required for the SNF Attachment, and emphasize the importance of accurate and timely reporting. Med-Net Academy offers the course Long-Term Care Survey Process, which reviews entrance requirements, the selection process for the survey sample, the phases of the survey, mandatory facility tasks completed at any time during the survey, triggered facility tasks based on surveyor concerns, and the purpose and scope of the Survey Pathways (formerly known as Critical Element Pathways). This course provides staff with practical guidance to help ensure readiness for regulatory oversight and survey compliance.
- Conduct audits to verify the accuracy and completeness of ownership, management, and other required disclosures, ensuring consistency between internal records and information submitted to CMS. Audits may also assess whether current processes identify gaps or delays that could affect compliance. Facilities may find it beneficial to engage an external reviewer or consultant to verify that all required ownership, management, and ADP disclosures have been accurately completed. This can help confirm that internal records align with CMS requirements, identify any remaining gaps, and support ongoing oversight prior to submission or final CMS review.
*This news alert has been prepared by Med-Net Concepts, Inc. for informational purposes only and is not intended to provide legal advice.*