For your radar: CMS continues to update its sub-regulatory guidance for the SNF Mandatory Off-Cycle SNF Provider Enrollment Revalidation process.

• Updates posted on November 26, 2024 include three important changes and updates in the following sections (see italicized text):

1. Updating Sections (I)(B) and (C) with clarifications regarding the May 1, 2025, due date.

• • CMS emphasizes that the SNF is NOT required to wait until May 1, 2025, to submit its revalidation application or the SNF Attachment. After receiving the application submission request from the MAC, the SNF may submit said application any time before May 1, 2025. 
  • The May 1, 2025, due date applies notwithstanding any alternative due date listed in the original application submission request letter from the MAC. To illustrate, suppose a SNF received a revalidation request from the MAC on October 10 with a listed due date 3 of January 5, 2025. The SNF may disregard the January 5 due date because the May 1, 2025, date applies. 
  • Note that the MACs will NOT be reissuing application request letters with the new May 1, 2025, due date listed. 

2. Updating FAQ #9 with information regarding the publication of SNF ownership data.

• • Q9: When and where will the public SNF data be published? Will it contain personally identifiable information (PII)?
  • A: It has been posted on data.gov as part of the SNF dataset we currently publish at https://data.cms.gov/provider-characteristics/hospitals-and-other-facilities/skilled-nursing-facility-all-owners. As with previously posted SNF ownership data at the above link: (1) PII will not be disclosed; and (2) all Privacy Act protections will be maintained.

3. Adding new FAQ #14 concerning non-receipt of revalidation letters.

• • Q14: It is late December 2024, and we still have not received a revalidation request letter. What should we do?
  • A: CMS recommends that the SNF contact its MAC for information (e.g., whether the letter was sent, etc.).

Also of note: CMS has updated information on provider enrollment data for all currently Medicare-enrolled SNFs on Data.CMS.gov to include new data fields associated with Private Equity and Real Estate Investment Trust ownership, as well as Additional Disclosable Parties (ADPs).

• Read AHCA/NCAL’s blog post for more details.

Help for providers: AHCA/NCAL will continue to update and share member resources during this process, including on its website, as well as assist members through the member Provider Enrollment Revalidation Helpdesk.

• Additionally, AHCA/NCAL will also host Office Hours webinars on December 6, 2024, January 10, 2025, and January 31, 2025.