​The Centers for Medicare & Medicaid Services (CMS) recently issued an announcement in the MLN Connects newsletter 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. This information is to be submitted in a new Appendix on the Form CMS-855A (09/24) version.   

WHAT YOU NEED TO KNOW

1. 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.  
2. 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) system to keep their provider enrollment status active.
3. The requested information is quite complex and affects every SNF, regardless of size or ownership characteristics.
4. SNF providers no longer report in Sections 5 and 6 of the provider enrollment form, but in a new SNF-specific Appendix. Instructions for the new SNF Appendix are here.  
5. In addition to SNF revalidation timeline discussed above, the new Form CMS-855A must be used for all of the following provider enrollment transactions effective October 1, 2024:

                    a. Initial Enrollment

                    b. Revalidations

                    c. Reactivations

                    d. 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 Appendix be completed by the SNF provider.  

WHAT YOU NEED TO DO

1. Review the new Form CMS-855A and the new GUIDANCE FOR SNF ATTACHMENT ON FORM CMS-855A.
2. CMS and AHCA/NCAL suggest providers seek counsel from an attorney to help interpret the new SNF reporting requirements.  
3. Begin compiling the new information that will be required to be reported ASAP.
4. 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.