Medicare Revalidation Deadline for SNFsSubmit in PECOS by August 1, 2025

4/28/2025 - By Cade Crawford

IMPORTANT ANNOUNCEMENT - MEDICARE SNF REVALIDATION DEADLINE EXTENDED TO AUGUST 1, 2025

Last week, CMS announced that the mandatory off-cycle revalidation deadline had been extended until August 1, 2025. The announcement can be found here in the MLN Connects newsletter: 2025-04-17-MLNC | CMS.

With this extension, the required attachments for Form 855A are no longer due by the previous May 1, 2025 deadline. This extension allows SNF providers more adequate time to complete the required form and avoid having their Medicare payment eligibility revoked.

All providers should have received revalidation notices from their MAC intermediary on a staggered basis in late 2023. Despite the dates found in those notices, all providers now have until August 1, 2025, to submit the required information in PECOS to keep their enrollment status active.

IT IS IMPORTANT THAT SNF PROVIDERS COMPLETE THIS MANDATORY REVALIDATION ACTION IN ORDER TO KEEP YOUR ENROLLMENT STATUS ACTIVE.

This mandatory off-cycle revalidation process will now utilize the newly added Attachment 1: Skilled Nursing Facility Disclosures workpaper instead of Sections 5 & 6 of the enrollment form to complete this reporting.

Instructions on how to complete the new appendix section can be found here: SNF Attachment Public Subreg Guidance (cms.gov).

More information about the rulemaking behind the new mandatory reporting can be found here: Disclosures of Ownership and Additional Disclosable Parties Information for Skilled Nursing Facilities and Nursing Facilities; Definitions of Private Equity Companies and Real Estate Investment Trusts for Medicare Providers and Suppliers | CMS

HOW TO PREPARE

  1. Review the new forms CMS-855A (CMS-855A Medicare Enrollment Application Institutional Providers) as well as the appendix instructions (SNF Attachment Public Subreg Guidance (cms.gov))
  2. Confer with legal counsel to determine if there are potentially additional disclosable parties or other interpretations that apply to you as a SNF provider
  3. Immediately start to gather the required information as this reporting can be quite complex
  4. Start the reporting process in PECOS as soon as possible
  5. Complete the reporting in PECOS on or before August 1, 2025

If you have questions about these new revalidation requirements, or any other question concerning compliance, reimbursement, or operations for your skilled nursing facility, Saltmarsh’s team of experienced healthcare consultants can help. You can find all of the services our team can provide to your facility on our website - Healthcare Consulting | Saltmarsh CPA.

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