Mandatory Provider Enrollment Off-Cycle Revalidation for All SNFs
What’s happening: CMS announced that all skilled nursing facility (SNF) providers will receive off-cycle provider enrollment revalidation notices from their Medicare Administrative Contractor (MAC) to collect additional data on ownership, managerial, and related party information not previously required.
- SNFs must submit this information in a new Attachment on the Form CMS-855A (09/24) version.
- The requested information is quite complex and affects every SNF, regardless of size or ownership characteristics.
Be on the lookout for a letter from your MAC from October through December 2024 regarding a mandatory off-cycle revalidation. Approximately one-third of SNFs will receive these notices each month.
- Providers will have 90 days from the date of the letter to respond and submit the newly required information into the Medicare Provider Enrollment, Chain, and Ownership System (PECOS) to keep their provider enrollment status active.
How to report: SNF providers should now use the new SNF-specific Attachment, not Sections 5 and 6 of the provider enrollment form. Review these instructions for completing the new SNF Attachment.
In addition, the new Form CMS-855A must be used for all of the following provider enrollment transactions effective October 1, 2024:
- Initial Enrollment
- Revalidations
- Reactivations
- CHOW
Note: If the status of any SNF transaction for a-d above prior to October 1 is “pending” in PECOS as of October 1, the MAC will request the new Attachment be completed by the SNF provider.
Action for providers:
- Review the new Form CMS-855A and the new Guidance for SNF Attachment on Form CMS-855A.
- CMS and AHCA/NCAL suggest providers seek counsel from an attorney to help interpret the new SNF reporting requirements.
- Begin compiling the new information that will be required to be reported as soon as possible.
- Be on the lookout for an upcoming AHCA webinar on this new SNF provider enrollment reporting requirements.
Please contact Dan Ciolek or Martin Allen at AHCA/NCAL with questions.
