CMS Extends Off-Cycle Revalidation Deadline for Skilled Nursing Facilities to January 1, 2026, by Abbye Alexander, Esq., Christopher Tellner, Esq., and Henry Norwood, Esq., 8-12-2025

The Centers for Medicare & Medicaid Services (CMS) has extended —for the third time—the mandatory deadline for skilled nursing facilities (SNFs) to submit off-cycle Medicare revalidation documents.

The deadline to submit the updated CMS-855A with the new SNF attachment was originally May 1, 2025, then Aug. 1, 2025 and has now been extended by CMS to January 1, 2026. This extension offers SNFs crucial additional time to prepare for significant new requirements, but prompt action and careful planning are still strongly recommended.

What Is Medicare Revalidation?

Revalidation is the process by which Medicare providers confirm and update their enrollment information with CMS. Failure to complete this process by CMS deadlines can result in the deactivation of Medicare billing privileges—a critical threat to ongoing operations and revenue. Historically, revalidation focused on basic information about the facility and its ownership. However, CMS has imposed progressively stringent standards, particularly for SNFs to address concerns about the quality of care and facility operations, as outlined in a final rule CMS published in the Federal Register in November 2023 addressing the ownership disclosures.

Key Developments: Expanded Transparency and Disclosure

Below are some key takeaways from the updated off-cycle revalidation process:

Comprehensive Ownership Reporting:

SNFs must now identify and disclose all individuals and entities with any direct or indirect ownership or control interest, including:

1. • Each member of the SNF’s governing body.
   • Certain managing employees who directly or indirectly manage, advise, or supervise any element of the practices, finances, or operations of the SNF.
   • Parties involved in the facility’s organizational structure (this varies based on the type of organizational structure).

Indirect and Intermediate Layers:

Disclosure is required not only for immediate owners, but also for parties with indirect interests—such as management firms—across all intermediate layers.

Ancillary Relationships:

Among new categories of data that SNFs will have to report is a category called Additional Disclosable Parties (ADPs). ADPs include any person or entity who:

• Exercises operational, financial, or managerial control over the SNF or a part thereof, or provides policies or procedures for any of the SNF’s operations, or provides financial or cash management services to the SNF;
• Leases or subleases real property to the SNF, or owns a whole or part interest equal to or exceeding 5 percent of the total value of such real property; or,
• Provides management or administrative services, management or clinical consulting services, or accounting or financial services to the facility.

Attestation and Responsibility:

CMS takes these disclosures seriously and there will be consequences for facilities that do not report information completely and accurately including potential suspension or revocation of Medicare enrollment.

Recommended Next Steps to Consider

• Assemble a Dedicated Team:
  Engage compliance, legal, and financial professionals to coordinate all aspects of ownership and control mapping.
• Early Data Gathering:
  Begin gathering required information/documentation now—including for indirect and intermediate owners or entities.
• Review and Update Policies:
  Update policies and procedures to align with the expanded disclosure requirements.
• Monitor for Additional Guidance:
  CMS’ most recent sub-regulatory guidance is available here.

Conclusion

While the January 1, 2026 deadline offers extra time for compliance, the complexity and scope of the new revalidation requirements poses a significant regulatory shift for SNFs. Early preparation is essential to avoid interruptions in Medicare participation. Kaufman Dolowich will continue to monitor developments.

Authors: Abbye Alexander and Christopher Tellner, Co-Chairs of the Health Care/Managed Care Practice Group and Of Counsel Henry Norwood