Today, we received additional information from the Centers for Medicare and Medicaid Services (CMS) regarding the
mandatory off-cycle revalidation process for skilled nursing facilities (SNFs). The developments offer a delay for providers impacted by Hurricanes Helene and Milton, as well as offer all providers and vendors nationwide some additional support and relief with the reporting requirements.
Here's a brief summary of the updates from CMS:
- Due to disaster declarations, CMS will be extending the revalidation due dates for all SNFs in Florida, Georgia, South Carolina, North Carolina and Tennessee until May 1, 2025.
- CMS has scheduled an Open Door Forum for Thursday, October 17 where it will discuss expanded ownership disclosures.
- The agency released updated guidance on Friday, October 11 with an email address so providers can ask questions directly (SNFDisclosures@cms.hhs.gov).
- Earlier this week, CMS also updated sub-regulatory guidance so that fewer people have to report personal identifiable information, such as social security numbers and dates of birth.
Below is more information on each of these new developments.
Disaster DelayDue to disaster declarations, AHCA has been informed by CMS that all SNFs in the states of Florida, Georgia, South Carolina, North Carolina, and Tennessee will have until May 1, 2025, to submit their revalidation applications, regardless of:
- When they received their revalidation notification letter (i.e., October, November, and December).
- The particular county in which they're located in said state.
CMS says it will update the SNF sub-regulatory guidance to reflect this. As soon as that is made available, we will share that with AHCA/NCAL members.
For more information regarding the numerous, active disaster declarations from CMS, please visit their Current Emergencies
website.
CMS Open Door Forum on Thursday, October 17Thursday's Open Door Forum will include a section on the SNF Expanded Ownership, Management, and Related Party Reporting.
Date: Thursday, October 17, 2024Start Time: 2:00 PM – 3:00 PM Eastern Time (ET)Conference Leaders: Todd Smith & Jill Darling
Register in advance for this webinar:Meeting ID: 160 823 4591
Passcode: 200020
Contact CMS with any questions about the Open Door Forum:
SNF_LTCODF-L@cms.hhs.govMailbox for QuestionsA CMS e-mail address is now available to send your questions about this issue:
SNFDisclosures@cms.hhs.gov.
If you plan to contact CMS directly, we ask that AHCA members copy our dedicated email inbox (
855Revalidation@ahca.org) when they submit questions, so that we may track these with CMS.
Clarification for Additional Disclosable Parties (ADPs)On October 8, CMS updated its
sub-regulatory guidance (page 14 of Section VI[A]) to clarify that SNFs need only report the taxpayer identification numbers (TINs) and dates of birth (DOB) of the parties listed in that section. This effectively means that SNFs do not have to collect and disclose SSNs, TINs, and DOBs of ADPs and their ADPs' owners/managers, so long as those parties are not required to disclose because of other positions they hold, such as owners, directors, officers or managers of the SNF. Please see the full list of such parties in Section VI(A).
Parties that have policy questions beyond this guidance may e-mail
SNFDisclosures@cms.hhs.gov. Questions regarding the SNF's enrollment application should be directed to the SNF's applicable Medicare Administrative Contractors.
AHCA/NCAL SupportA friendly reminder that AHCA/NCAL is also offering two webinars on this issue: one for providers on Friday, October 18 and one for vendors on Monday, October 21.
Learn more on how to register.
Meanwhile, we are developing additional member resources to help support your data collection and submission efforts.
CMS may have a dedicated email address, but members are welcome to continue to reach out to AHCA with questions:
855Revalidation@ahca.org.