Nursing homes must prepare for an off-cycle revalidation process being mandated by the Centers for Medicare and Medicaid Services (CMS), or risk losing billing privileges.

With the extra paperwork, CMS aims to enhance the accuracy and transparency of Medicare enrollment information amid new reporting requirements finalized in 2023.

The revalidation notices will be dispatched by Medicare Administrative Contractors (MACs), with one-third of SNFs expected to receive them in October and the remainder in November or December, according to Clifton Larsen Allen (CLA) analysts.

Facilities will have a 90-day window from the notice date to submit updated information using a revised version of Form CMS-855A, which now includes sections to collect detailed ownership, management, and related-party transaction data, reflecting CMS’s increasing scrutiny on the operations of SNFs, particularly concerning private equity companies and real estate investment trusts.

Failure to comply with the new requirements could result in the inactivation of a facility’s provider enrollment status, leading to potential loss of billing capabilities.

In addition to this mandatory revalidation, CMS is requiring that starting Oct. 1, the new sections will be required for all provider enrollment transactions, including initial enrollments, revalidations, and changes of ownership.

Facilities with pending transactions prior to this date will need to update their submissions accordingly.