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Skilled Nursing Facility Disclosure Requirements

Foley & Lardner LLP

Update: CMS Extends Skilled Nursing Facilities’ Medicare Revalidation Deadline

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On July 17, 2025, the Centers for Medicare and Medicaid Services (CMS) announced an additional extension of the deadline by which skilled nursing facilities (SNFs) must revalidate their Medicare enrollments. Enrolled SNFs...more

Arnall Golden Gregory LLP

SNF Off-Cycle CMS-855A Reporting Delayed to January 1, 2026

The Centers for Medicare & Medicaid Services (“CMS”) has extended the window for skilled nursing facilities (“SNFs”) to file off-cycle Medicare revalidation documents until January 1, 2026. This marks CMS’ third deadline...more

Bond Schoeneck & King PLLC

CMS Delays Deadline for Nursing Home Federal Disclosures – August 1, 2025, Has Become January 1, 2026: Consider Support from Bond...

The Centers for Medicare and Medicaid Services (“CMS”) will be extending the deadline for the mandatory off-cycle revalidation process for Medicare-certified skilled nursing facilities (SNFs). The revised deadline is Jan. 1,...more

Epstein Becker & Green

Pushback of Deadline for SNFs to Submit Significantly More Detailed Ownership and Control Information in New “SNF Attachment” to...

Epstein Becker & Green on

With newly confirmed Dr. Mehemet Oz at its helm, the Centers for Medicare & Medicaid Services (CMS) maintained but delayed the deadline for its requirement that Skilled Nursing Facilities (SNFs) to report significantly...more

Nelson Mullins Riley & Scarborough LLP

Attention SNFs: Enhanced 855A Disclosure Requirement Deadline Extended to August 1, 2025

This article is an update to a December 2024 client alert. On April 17, 2025, the Centers for Medicare and Medicaid Services ("CMS") extended the revalidation deadline for its 855A skilled nursing facility...more

Foley & Lardner LLP

Skilled Nursing Facilities: CMS Extends Medicare Revalidation Deadline

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On April 17, 2025, the Centers for Medicare and Medicaid Services (CMS) announced another extension of the deadline by which skilled nursing facilities (SNFs) must revalidate their Medicare enrollments: Enrolled skilled...more

McDermott Will & Emery

CMS Updates SNF Attachment Guidance Ahead of May 1 Enrollment Deadline

McDermott Will & Emery on

Skilled nursing facilities (SNFs) historically have been required to disclose ownership and managerial control information as part of their Medicare enrollment. However, these requirements were significantly expanded to...more

Bricker Graydon LLP

The Mandatory SNF Provider Enrollment Revalidation Deadline is May 1, 2025

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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...more

Sheppard Mullin Richter & Hampton LLP

Deadline Quickly Approaching for NY Nursing Homes and Owners/Operators Regarding CMS Star-Rating Postings

Effective as of December 26, 2024, each nursing home facility (“Facility”) in New York State will be required to post its overall Centers for Medicare & Medicaid Services (“CMS”) rating, as well as its ratings for (i) health...more

Baker Donelson

Updates to SNF Off-Cycle Revalidation Guidance Continue

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As skilled nursing facilities (SNFs) seek to understand and meet the new expansive Medicare enrollment reporting obligations, the Centers for Medicare and Medicaid Services (CMS) issued several updates to its Guidance for SNF...more

Dentons

Ep. 40 – Complying with Expanded Medicare Disclosure Requirements for Skilled Nursing Facilities

Dentons on

The Centers for Medicare & Medicaid Services (CMS) is in the midst of an off-cycle revalidation process for all Medicare-participating skilled nursing facilities (SNFs), requiring them to submit much more information...more

Polsinelli

Calling All SNFs… and All of Your Operational Associates – Get Ready Now: Sweeping New Disclosure Requirements Under The Updated...

Polsinelli on

Skilled Nursing Facilities and their operational associates need to prepare themselves now for new disclosure requirements that require much greater disclosure of ownership as well as disclosure from a much broader class of...more

Holland & Knight LLP

Significant Changes to SNF Disclosure Requirements Prompt Need for Regulatory Review

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To enhance quality of operations and increase transparency in ownership within skilled nursing facilities (SNFs), the Centers for Medicare & Medicaid Services (CMS) issued its Final Rule for ownership disclosures for Medicare...more

Arnall Golden Gregory LLP

CMS Releases Update to CMS-855A Enrollment Form With Significant Increase in Disclosure Requirements for SNFs

The Centers for Medicare & Medicaid Services (“CMS”) has issued an updated version of the Form CMS-855A that requires additional disclosures for skilled nursing facilities (“SNFs”). Effective October 1, 2024, the revised Form...more

Mintz - Health Care Viewpoints

Off-Cycle Nursing Facility Revalidations Are Starting: Is Your SNF Ready for the Required Disclosures?

Commencing October 2024, CMS will start off-cycle revalidations of all Skilled Nursing Facilities (SNFs). As part of the revalidation process, SNFs must disclose the additional information required under CMS’ final rule,...more

K&L Gates LLP

The Wait Is Over: Revised CMS Enrollment Form Puts SNF Ownership and Management Under a Microscope

K&L Gates LLP on

With the release of an updated CMS-855A enrollment form (855A), skilled nursing facilities (SNFs) will be required to identify substantially more detailed ownership and control information to Centers for Medicare and Medicaid...more

Fox Rothschild LLP

CMS to Require All Skilled Nursing Facilities to Complete Off-Cycle Revalidation

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The Centers for Medicare & Medicaid Services (CMS) recently announced it will require off-cycle revalidation of skilled nursing facilities (SNFs) through the end of 2024. During this process, CMS will collect ownership,...more

ArentFox Schiff

The 10 Trends and Legal Challenges We Are Tracking Throughout 2024

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With 2024 well underway, this article highlights some of the pressing legal issues impacting the long term care and senior housing industry this year, including trends affecting the industry and emerging issues industry...more

McDermott Will & Emery

Healthcare Regulatory Check-Up Newsletter | November 2023 Recap

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This issue of McDermott’s Healthcare Regulatory Check-Up highlights regulatory activity for November 2023. We discuss several US Department of Health and Human Services (HHS) agency actions, including the new General...more

Davis Wright Tremaine LLP

Ownership Transparency: The New Normal in Healthcare?

On November 17, 2023, the U.S. Department of Health and Human Services ("HHS") Centers for Medicare and Medicaid Services ("CMS") published a final rule (the "Final Rule") requiring Medicare skilled nursing facilities...more

McDermott Will & Emery

Private Equity and REITs, Take Note! CMS Finalizes Nursing Facility Ownership Disclosure Requirements

McDermott Will & Emery on

On November 17, 2023, the US Department of Health and Human Services (HHS) published a final rule requiring nursing facilities participating in Medicaid and skilled nursing facilities participating in Medicare to disclose...more

Arnall Golden Gregory LLP

UPDATE: CMS Finalizes Rule Requiring Greater SNF Ownership Transparency, Including Private Equity and REIT Disclosures, and...

The Centers for Medicare & Medicaid Services (“CMS”) released a final rule on November 15, 2023 (published on November 17, 2023) (the “Rule”), requiring greater skilled nursing facility (“SNF”) ownership transparency. The...more

BCLP

New Final Rule Requires U.S. Nursing Homes Disclose Ownership Structure

BCLP on

On November 17, 2023, the Centers for Medicare and Medicaid (CMS) published a final rule implementing additional disclosure requirements for U.S.-located, Medicare skilled nursing facilities and Medicaid nursing facilities...more

McCarter & English, LLP

Next Stop, Revalidation Station: CMS Final Rule for Nursing Home Transparency to Prompt Off-Cycle Revalidation, Revised Form...

Nursing facilities should prepare to provide the Centers for Medicare & Medicaid Services (CMS) with additional information about their ownership, their managing employees and the parties providing certain financial and...more

Goodwin

Additional Disclosure Required: CMS Implements Substantial Changes to Reporting Skilled Nursing Facility Ownership Information

Goodwin on

On November 15, 2023, the Centers for Medicare & Medicaid Services (CMS) issued a Final Rule that will require skilled nursing facilities (SNFs) to disclose an expanded array of ownership, managerial, and control information...more

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