Here’s What You Need to Know
The Centers for Medicare and Medicaid Services (CMS) has long required skilled nursing facilities (SNFs) enrolled in the Medicare and Medicaid programs to disclose information regarding organizational structure, governing body, and officers as part of their enrollment, revalidation, reactivation, or change of ownership (CHOW) applications. On November 17, 2023, CMS published a final rule implementing parts of 1124(c) of the Social Security Act with newly required reporting terms and replacing Sections 5 and 6 of the CMS 855A enrollment form with Attachment 1. While there have been updates since the final rule’s release, including extending the initial deadline, all SNFs must now submit an off-cycle revalidation by May 1, 2025.
1124(c) requires SNFs to disclose (i) members of its governing body; (ii) each person or entity who is an officer, director, member, partner, trustee, or managing employee; (iii) each person or entity who is an additional disclosable party; and (iv) the organizational structure of each additional disclosable party and a description of the relationship of each additional disclosable party to the SNF and to one another.
The definition of who constitutes an additional disclosable party is nuanced, and CMS has categorized additional disclosable parties into 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.
Why it Matters:
Failure to revalidate by the May 1, 2025, deadline may result in the suspension or revocation of Medicare payments.
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