CMS Extends 855A Revalidation Due Date: Advocacy Win

Recommend

On behalf of our nursing home members, LeadingAge urged CMS to reconsider aspects of the revalidation process and timeline, with specific emphasis on the limited time for compliance, the extensive data requirements, and the expanded list of disclosable parties.

Guidance released November 5 by the Centers for Medicare and Medicaid Services (CMS) extends to May 1, 2025 the deadline for nursing homes to complete the revalidation process. Prior to the agency's most recent announcement, the due date for compliance with nursing home transparency reporting requirements was October 1, 2024 as outlined in the SNF Attachment on Form CMS-855A.

The 855A revalidation due date extension follows sustained advocacy by LeadingAge, beginning in 2023. For more than a year, we've closely monitored the CMS' actions related to transparency in nursing home ownership and management, which is a priority for the current administration; we've urged CMS to reconsider aspects of the revalidation process and timeline, with specific emphasis on the limited time for compliance, the extensive data requirements, and the expanded list of disclosable parties.

Importantly, this new timeline now applies uniformly across all states, whereas states affected by Hurricanes Helene and Milton had previously been granted extensions. The November 5 changes and updates also clarifies the number of organizational charts that must be submitted and provides Frequently Asked Questions.

Other details on the November 5 guidance is as follows: Due Dates for All SNFs Regardless of when the SNF received its notice of revalidation letter from its MAC (i.e., October, November, or December), the revalidation application due date for ALL SNFs - irrespective of the state in which they are located - is May 1, 2025. This May 1, 2025, due date also applies to ALL SNFs that - as explained in Section (I)(B) above - had a pending initial, revalidation, reactivation, or CHOW application as of October 1, 2024, and were requested to submit the SNF Attachment. The Attachment will not be due until May 1, 2025. The previous restriction of the May 1, 2025, date to SNFs in Florida, Georgia, South Carolina, North Carolina, and Tennessee no longer applies.

LeadingAge will continue to monitor the guidance and update members with any changes. In addition, we will continue to engage with members regarding issues and concerns with the revalidation process in order to advocate for potential future changes in the process. If your organization is in the revalidation process currently, we want to hear from you. Please contact Janine Finck-Boyle.