SNFs now have until August 1, 2025 to submit Medicare revalidations.
In October, we broke down the required off-cycle Medicare revalidation of all Skilled Nursing Facilities (SNFs) in an Alert and related blog post. We were happy to announce in November that CMS extended the deadline for SNFs to submit such revalidations until May 1, 2025. Since our last update, CMS has further extended the submission deadline to August 1, 2025.
The change likely reflects the intensive process required for revalidation, especially given the addition of Attachment 1, which for the first time collects new categories of information on topics including ownership, management, organization, and administration. As of mid-March, the American Health Care Association and National Center for Assisted Living (AHCA/NACL) reported that less than 20% of SNFs had submitted revalidation applications. Even those facilities that have already submitted revalidation applications have seen them returned with requests from CMS for additional information, highlighting the onerous requirements of the new process. Failure to submit a revalidation application bears the risk of Medicare enrollment suspension or revocation, so timely submission is critical.
CMS also updated its guidance on April 9, 2025 for SNFs completing revalidation. Updates include additions to Section IV and the FAQs regarding requirements for reporting Additional Disclosable Parties (ADPs). SNFs are encouraged to carefully review the guidance and continue to check for updates throughout the process of submitting their revalidation applications. What should your facility do in light of this new information? Check out our updated alert here: CMS Extends Deadline for All Skilled Nursing Facilities to Complete Required Off-Cycle Revalidation, plan ahead and expect an intensive process.
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