CMS Updates Guidance for Mandatory Off-Cycle SNF Provider Enrollment Revalidations

CMS; Skilled Nursing Facilities (SNF); Medicare
 
Published:November 26, 2024
Dan Ciolek
​The Centers for Medicare and Medicaid Services (CMS) today, November 26, updated its sub-regulatory guidance for the SNF Mandatory Off-Cycle SNF Provider Enrollment Revalidation process. This update includes three important changes and updates in the following sections (see italicized text): 

  1. Updating Sections (I)(B) and (C) with clarifications regarding the May 1, 2025, due date. 
  • CMS emphasizes that the SNF is NOT required to wait until May 1, 2025, to submit its revalidation application or the SNF Attachment. After receiving the application submission request from the MAC, the SNF may submit said application any time before May 1, 2025. 
  • The May 1, 2025, due date applies notwithstanding any alternative due date listed in the original application submission request letter from the MAC. To illustrate, suppose a SNF received a revalidation request from the MAC on October 10 with a listed due date 3 of January 5, 2025. The SNF may disregard the January 5 due date because the May 1, 2025, date applies. 
  • Note that the MACs will NOT be reissuing application request letters with the new May 1, 2025, due date listed. 
 
  1. Updating FAQ #9 with information regarding the publication of SNF ownership data. 
  • Q9: When and where will the public SNF data be published? Will it contain personally identifiable information (PII)? 
  1. Adding new FAQ #14 concerning non-receipt of revalidation letters. 
  • Q14: It is late December 2024, and we still have not received a revalidation request letter. What should we do? 
  • A: CMS recommends that the SNF contact its MAC for information (e.g., whether the letter was sent, etc.).