CMS recently extended the deadline for the mandatory SNF provider enrollment off-cycle revalidation to January 1, 2026.
As we wrote about previously, CMS issued a significant off-cycle mandate requiring all skilled nursing facilities (SNFs) in the US—both for-profit and nonprofit—to revalidate their Medicare provider enrollment records. Originally due by May 1, 2025, then August 1, 2025, the deadline has now been extended to January 1, 2026, giving facilities additional time to comply. This revalidation is essential to maintain Medicare billing privileges and incorporates more rigorous disclosure requirements than ever before.
The updated process centers around expanded transparency in ownership and control structures. SNFs must report detailed information on all individuals and entities with ownership or managerial roles, including a new category called Additional Disclosable Parties (ADPs). These include anyone who exercises operational, financial, or managerial control, provides real estate, or delivers services such as consulting or accounting. CMS has updated Form CMS-855A and developed a 20-page SNF-specific attachment to capture this information, along with detailed guidance to help facilities navigate the changes.
The scope of disclosure has also broadened to include parties with formal and informal influence over SNF operations, such as managing employees, consultants, and organizations with financial or operational oversight. Facilities must report granular data on both individuals and organizations, such as ownership percentages, tax IDs, NPIs, and the nature of their relationship to the SNF. The complexity of these requirements makes it critical for SNFs to assess their internal structures, collect necessary documentation, and continue to evaluate management and other changes on a routine basis. Among the many supporting documents required for this effort, CMS is placing a significant emphasis on an organizational chart that outlines the relationships of all organizations and individuals disclosed within the revalidation application.
To support compliance, CMS encourages the use of its PECOS online portal for submissions and offers help through various channels. Many SNFs are also turning to legal counsel and credentialing professionals for guidance. Firms like BerryDunn have developed tools and resources to help facilities organize and track the required data. While the new January 1, 2026, deadline allows an additional runway, SNFs are encouraged to complete this recertification as soon as possible. Proactive planning and responding to any additional requests (CMS allows a 30-day window for corrections once applications are submitted) is essential to avoid disruptions in Medicare participation.
We're here to help
As you prepare, it can be helpful to work with an experienced team of credentialing professionals who will help you navigate the complex process of meeting the new revalidation requirements. BerryDunn’s Credentialing and Enrollment Team is available to offer guidance and support to client organizations as they collect, organize, and track ownership, control, and ADP information, and to guide them through the CMS revalidation process. Additional CMS resources are available, including a dedicated email, SNFDisclosures@cms.hhs.gov, and PECOS support, via the External User Services (EUS) Help Desk. The Help Desk can also be reached by phone at 1.866.484.8049 or email at EUS_Support@cms.hms.gov.