In a significant regulatory development that will impact every skilled nursing facility in the United States, the Centers for Medicare and Medicaid Services (CMS) has launched a comprehensive initiative requiring all SNFs to revalidate their Medicare provider enrollment. This sweeping mandate, announced in late 2024, introduces unprecedented disclosure requirements that extend far beyond traditional ownership reporting. While primarily aimed at increasing transparency in for-profit nursing homes, private equity investors, and chain operations, these new requirements will affect facilities of all types – including not-for-profit and government-sponsored institutions. With facilities receiving notices through year-end 2024 and facing just 90 days to comply, understanding and preparing for these new requirements is critical for maintaining Medicare participation.

Key Takeaways

• All skilled nursing facilities must revalidate Medicare enrollment by submitting a new CMS Form 855A
• Facilities will receive notices by end of 2024 with 90-day completion deadline
• New requirements affect both for-profit and non-profit facilities
• Extensive disclosure needed for ownership, control, and service providers

Breaking Down the New Requirements

The Centers for Medicare and Medicaid Services (CMS) has announced a significant change affecting all skilled nursing facilities (SNFs). This off-cycle enrollment revalidation initiative requires comprehensive disclosure of facility ownership and control structures through a new CMS Form 855A.

Timeline and Process

• Notices will be distributed by Medicare Administrative Contractors (MACs) by year-end 2024
• Facilities have 90 days to complete the new Form 855A
• Implementation will occur in phases
• Guidance is being released on a rolling basis

Who Must Be Disclosed?

The new form introduces the concept of “Additional Disclosable Parties” (ADPs), which includes any person or entity who:

1. Exercises Control:

• •    Operational oversight
  •    Financial management
  •    Managerial authority
  •    Policy/procedure development

2. Provides Real Estate:

• •    Property lessors/sublessors
  •    Owners of ≥5% interest in facility property

3. Delivers Services:

• •    Management services
  •    Administrative support
  •    Clinical consulting
  •    Financial services
  •    Accounting services

Understanding Financial and Operational Control

Financial Control Examples

• Budget monitoring/management
• Expenditure approval authority
• Funding operations
• Credit line providers

Operational Control Examples

• Medical records oversight
• Patient activities management
• Dietary operations supervision
• Daily activity oversight

Service Provider Disclosure Requirements

Management and Administrative Services

• Compliance oversight
• Human resources
• Public relations/marketing
• IT system support
• Facility management

Financial and Clinical Services

• Investment management
• Asset management
• Accounting/auditing services
• Clinical assessment/advisory
• Cash flow management

Action Steps for SNFs

1. Immediate Actions:

• • Review the new Form 855A
  • Begin identifying all ADPs
  • Document existing service relationships
  • Consult with legal counsel

2. Preparation Steps:

• • Gather ownership documentation
  • Review service provider contracts
  • Document control relationships
  • Prepare disclosure information

Important Notes

• Requirements apply to both for-profit and non-profit facilities
• Guidance continues to evolve
• Legal consultation is recommended
• Questions can be submitted directly to CMS

Stay Informed

For the latest updates and detailed guidance:

• Monitor CMS communications
• Follow MAC announcements
• Consult healthcare legal counsel
• Watch for additional guidance releases

Get Expert Support

Don’t navigate these complex requirements alone. Grassi’s Healthcare Advisors bring decades of experience in healthcare compliance and regulatory requirements to help your facility successfully complete the revalidation process.

How Grassi Can Help:

• Guide you through the new Form 855A requirements
• Identify and document your Additional Disclosable Parties
• Review your current service provider relationships
• Ensure complete and accurate submissions
• Develop compliance processes for ongoing requirements

Contact Us Today

Ready to ensure your facility’s compliance with these new CMS requirements? Contact Grassi’s Healthcare Advisory team. Our experienced healthcare advisors are ready to help you navigate this complex revalidation process and ensure your facility maintains full compliance with CMS requirements.

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