What’s new: AHCA has shared additional information from CMS about the mandatory off-cycle revalidation process for skilled nursing facilities (SNFs).

• The developments offer a delay for providers impacted by Hurricanes Helene and Milton, as well as offer all providers and vendors nationwide some additional support and relief with the reporting requirements.

AHCA/NCAL Support: AHCA/NCAL is also offering two webinars on this issue: one for providers on October 18 and one for vendors on October 21. Learn more on how to register.

• AHCA is also developing additional member resources to help support your data collection and submission efforts. Members may send questions to 855Revalidation@ahca.org.

Details about the CMS updates:

1. Due to disaster declarations, CMS will be extending the revalidation due dates for all SNFs in Florida, Georgia, South Carolina, North Carolina, and Tennessee until May 1, 2025.

1. CMS has scheduled an Open Door Forum for October 17 where it will discuss expanded ownership disclosures.
2. The agency released updated guidance on October 11 with an email address so providers can ask questions directly (SNFDisclosures@cms.hhs.gov).
3. CMS also updated sub-regulatory guidance so that fewer people have to report personal identifiable information, such as social security numbers and dates of birth.  

Due to disaster declarations, AHCA has been informed by CMS that all SNFs in the states of Florida, Georgia, South Carolina, North Carolina, and Tennessee will have until May 1, 2025, to submit their pending initial, revalidation, reactivation, or CHOW applications, regardless of:

1. When they received their revalidation notification letter (i.e., October, November, and December).
2. The particular county in which they are located in said state.

CMS says it will update the SNF sub-regulatory guidance to reflect this. As soon as that is made available, we will share that with AHCA/NCAL members.

• For more information regarding the numerous, active disaster declarations from CMS, please visit their Current Emergencies website.

CMS Open Door Forum: CMS will host an SNF Open Door Forum on October 17, 2024 at 2:00pm, that includes discussion of the SNF Expanded Ownership, Management, and Related Party Reporting.

• Miss the forum? Transcripts and audio recordings of SNF Open Door forms are posted online.

Mailbox for questions: A CMS email address is now available to send your questions about this issue: SNFDisclosures@cms.hhs.gov.

• If you plan to contact CMS directly, we ask that AHCA members copy our dedicated email inbox (855Revalidation@ahca.org) when they submit questions, so that we may track these with CMS.

Clarification for Additional Disclosable Parties (ADPs): On October 8 and 15, 2024, CMS updated its sub-regulatory guidance (page 14 of Section VI[A]) to clarify that SNFs need only report the taxpayer identification numbers (TINs) and dates of birth (DOB) of the parties listed in that section. This effectively means that SNFs do not have to collect and disclose SSNs, TINs, and DOBs of ADPs and their ADPs’ owners/managers, so long as those parties are not required to disclose because of other positions they hold, such as owners, directors, officers, or managers of the SNF. Please see the full list of such parties in Section VI(A).

• Parties that have policy questions beyond this guidance may email SNFDisclosures@cms.hhs.gov. Questions regarding the SNF’s enrollment application should be directed to the SNF’s applicable Medicare Administrative Contractors.