The Centers for Medicare & Medicaid Services has initiated an off-cycle revalidation process for skilled nursing facilities, requiring providers to submit updated enrollment information within 90 days of receiving notice. The initiative, first announced in October 2024, represents CMS’s most comprehensive nursing home enrollment review since the implementation of enhanced provider screening requirements under the Affordable Care Act.
Revalidation Requirements
Facilities receiving revalidation notices must submit updated information using a revised version of Form CMS-855A, the Medicare enrollment application for institutional providers. Key information requiring verification includes: ownership and managing control interests, authorized officials and delegated officials, practice location information, and compliance with state licensure requirements.
CMS has emphasized that the revalidation process includes enhanced screening for facilities designated as “high risk” based on prior compliance history. High-risk facilities may be subject to site visits and more extensive documentation requirements.
Timeline and Consequences
Facilities have 90 days from the date of the revalidation notice to submit complete and accurate information. Failure to respond or submission of incomplete information can result in deactivation of Medicare billing privileges. CMS has indicated it will provide a 30-day warning before any deactivation takes effect.
Industry groups have raised concerns about the administrative burden of the revalidation process, particularly for facilities with complex ownership structures involving multiple entities.
Ownership Transparency Focus
The revalidation process aligns with broader CMS initiatives to improve ownership transparency in the nursing home sector. Facilities must now report ownership interests at the 5% threshold, down from 25% previously, and must disclose certain related-party transactions.
CMS has stated that accurate ownership information is essential for identifying patterns of poor performance across commonly-owned facilities and for holding owners accountable for care quality.