CMS Open Door Forum, First in Months, Dives into Medicare Revalidation Process for Nursing Homes

The Centers for Medicare & Medicaid Services (CMS) went over the off-cycle Medicare revalidation process for nursing homes in its latest open door forum on Thursday, its first in several months.

About one-third of all providers will receive a letter from their Medicare administrative contractor (MAC) between this month and December requesting completion of the revalidation form, Frank Whelan, technical advisor for CMS, said during the open door forum.

Notably, five states affected by Hurricanes Helene and Milton will have more time to complete the Medicare revalidation process.Whelan said Florida, Georgia, Tennessee, North Carolina and South Carolina will have until May 1, 2025 to finish the revalidation, even if they’ve received letters from their MAC saying otherwise.

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It doesn’t matter when the SNF in these states received their revalidation letter, even if they received it this month, they will still have until May 1 2025 to submit their application, Whelan said, and revalidation application fees and site visits will also be waived for SNFs in these states, to the extent that the site visit has not already been performed and fee has not been paid.

The May 2025 extension also applies to change of ownership (CHOW) applications, pending initial revalidation, or Medicare reactivations for these five states, Whelan said.

More generally, Whelan said SNF providers have long been required to disclose various ownership and managerial information under the Social Security Act, but a final rule in November 2023 requires providers to disclose detailed information about their ownership and management along with other parties in which the facility is associated.

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“We posted very detailed subregulatory guidance on our CMS provider enrollment website and this outlines the statutory and regulatory requirements. It outlines who needs to be reported, which entities or which individuals, and how to complete each section,” Whelan said of the additional ownership and party affiliation added with last year’s final rule.

This guidance will be updated over the coming weeks and months, he added – constant updates to address issues as they arise.

He explained the off-cycle revalidation in terms of three layers, the first layer being what is already collected regarding ownership and management. The second layer goes “a little bit beyond” the currently reported managing organizations, adding entities that provide certain services to the facility, like cash management services and accounting services.

The third layer is reporting certain ownership and managerial interest in the additional disclosable parties, he said.

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