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

4/28/2025 - By Cade Crawford

IMPORTANT REMINDER - AUGUST 1, 2025 MEDICARE SNF REVALIDATION DEADLINE RAPIDLY APPROACHING

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 have until August 1, 2025, to submit the required information in PECOS to keep their enrollment status active. Failure to submit your completed revalidation forms by the August 1 deadline will result in your Medicare provider number being suspended or deactivated. This action would lead to all Medicare billing being paused until the provider is determined to be in compliance with the reporting requirements again.

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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