The Centers for Medicare and Medicaid Services (CMS) is once again delaying the deadline to file revalidation paperwork, moving it from May 1 to August 1. It’s a welcome relief for operators given that a vast majority of nursing homes haven’t completed the burdensome paperwork.

Martin Allen, senior vice president of reimbursement policy at the American Health Care Association and National Center for Assisted Living (AHCA/NCAL), said CMS heard the providers’ plea.

“We are grateful that CMS has delayed the revalidation deadline and has been open to hearing from providers throughout the process,” Allen said in an emailed statement to Skilled Nursing News. “We support transparency, but policymakers must balance and streamline policies to ensure that disclosure requirements are meaningful, achievable, and clear.”  

This impacts all Medicare-enrolled skilled nursing facilities that have not had an enrollment transaction completed after October 1, 2024, which is the date that CMS introduced the updated disclosures submission policy specifically for skilled nursing facilities. Of the 15,000 facilities nationwide, this affects about 14,000 of them, according to provider sources.

In mid-March, about 80% of SNFs had not yet submitted their off-cycle revalidation, CMS told provider sources.

The federal agency also indicated that it will post official updates to its Medical Learning Network (MLN), likely via the MLN Connects newsletter.

‘Vast majority’ unable to complete paperwork

Mike Nickolaus, CEO of EF Senior Care, who has been on top of the paperwork ever since CMS issued the final rule – effective in October of last year, only for the filing deadline to be delayed to May 1 – attested to the arduousness of the process.

And, it comes as no surprise that most operators haven’t been able to complete it, Nickolaus told SNN.

Nursing homes, which are required to gather information on affiliations and disclose all ownership details on Form CMS-855A, have not yet begun sending requests for information – indicating they may be struggling to meet the May 1 deadline.

“I’d guess that the vast majority of SNFs won’t meet the deadline,” Nickolaus said. “In addition to our own facilities, we’ve been contracted to assist other facilities and I’m stunned how many prominent additional disclosable parties such as accounting firms, lenders, staffing agencies, etc., haven’t heard about it. That suggests that SNFs aren’t reaching out to them yet.”  

EF Senior Care owns and operates facilities, and also provides consulting services to facilities in the Northeast region. It has assisted over 150 facilities with administrative, clinical, back office and financial support.

Part of the slow going may have to do with CMS’ initial requirements: Only certain facilities – those with new acquisitions – were at first required to file the off-cycle revalidation paperwork.

“Last fall the issue was faced by only those SNFs seeking to become Medicare certified,” Nickolaus said. “However, ever since CMS postponed the deadline to May 1, every SNF in the country was required to complete it.”

SNN reached out to CMS, but a response was not available at the time of publication.

Cumbersome but necessary

Burdens aside, most providers aren’t against the paperwork. However, all acknowledge that more time is needed to complete it.

At LeadingAge, the largest association of nonprofit providers of senior care, including nursing homes, Linda Couch, SVP of policy, applauded the news of the delay.

“Today’s decision by the Centers for Medicare and Medicaid Services is a validation of our long-standing position that this is an important requirement that we support and, due to the detailed nature of the information needed to comply, more time is needed,” Couch said in an emailed statement to SNN.

In October 2024, CMS announced an off-cycle Medicare revalidation process for nursing homes, aimed at improving transparency and accuracy in enrollment data under new reporting rules finalized in 2023.

Medicare Administrative Contractors (MACs) began sending notices to SNFs in waves starting that fall, giving each facility 90 days to respond.

The updated process requires providers to submit a revised ownership disclosure form, which now includes expanded sections on ownership, management, and related-party transactions.

Under the Biden administration, the changes reflected CMS’ growing scrutiny over ownership structures at nursing homes, especially those linked to private equity firms and real estate investment trusts.

CMS mandated that all provider enrollment transactions – including new enrollments, revalidations, and changes of ownership – must include the new disclosure information.

Failure to comply with the requirement could lead to inactivation of a facility’s Medicare billing privileges.

AHCA’s Allen said his organization will provide its assistance to providers for these compliance goals.

“We will continue to support nursing home providers as they work to comply with these revalidation requirements, and we look forward to an ongoing dialogue with CMS about ways to prioritize patients over paperwork.”

Providers can get more information at: https://www.cms.gov/medicare/enrollment-renewal/providers-suppliers/chain-ownership-system-pecos