Providers Required to Submit Managing Employee Information to Provider Enrollment Records Immediately

Skilled Nursing Facilities (SNF); Compliance; CMS

On February 8, the Centers for Medicare and Medicaid Services (CMS) MLN Connects newsletter clarified for providers that

“…hospice and skilled nursing facility medical directors and administrators are always considered managing employees for Medicare provider enrollment purposes. You must report all current managing employees. If you haven’t reported a medical director or administrator, report them now.” 
Per an email to AHCA/NCAL from CMS, the information referenced in the MLN notice can be furnished via a CMS-855A change of information (COI) submission. SNFs can obtain info about the COI process for reporting SNF medical directors and administrators via the CMS enrollment website or by contacting their local MAC.   
Prior to this notice, it was unclear whether recent regulatory changes explicitly requiring these individuals to be reported on SNF provider enrollment documentation be submitted via a COI submission, or during the next revalidation period. This notice provides clarification that providers should not wait for the revalidation and must submit any missing medical director or administrator via the COI submission as soon as possible.     
Additional Information 

In the CMS November 17, 2023 final rule Disclosures of Ownership and Additional Disclosable Parties Information for Skilled Nursing Facilities and Nursing Facilities; Medicare Providers’ and Suppliers’ Disclosure of Private Equity Companies and Real Estate Investment Trusts (CMS-6084-F), CMS revised the regulatory definition of “Managing Employee” in 42 CFR 424.502 to explicitly include “…a hospice or skilled nursing facility administrator and a hospice or skilled nursing facility medical director.” 
Providers should reference the Medicare Program Integrity Manual on CY 2024 Home Health Prospective Payment System Updates MLN Matters article; it has more information on how that payment rule includes changes to the Medicare Program Integrity manual, including how CMS revised the definition of “managing employee” that also impacts SNFs.