We’re here to ensure you have the most up-to-date information on critical regulatory changes! Since our last blog, “Avoid Disruption in Billing – CMS Mandatory Off-Cycle SNF Provider Revalidation,” new developments have been announced. To keep everything in one place, we’ve added these important updates to the blog and will continue to provide more details as they become available.
Update: 10/21/2024
Key Details:
- Due to disaster declarations, CMS extended the revalidation due date to May 1, 2025, for SNFs in FL, GA, SC, NC & TN.
- CMS instructed listeners on the 10/17/24 Open Door Forum to monitor their Subregulatory Guidance on this updated 855-A document for ongoing clarification, updates and requirements.
- A CMS e-mail address is available to send your questions about this issue: SNFDisclosures@cms.hhs.gov.
Need Assistance?
- Guided Care is a trusted resource that can help facilities complete and submit the required updates.
- To connect with a Guided Care representative, contact JoLynn Culpepper at jculpepper@qrmhealth.com.
Original Post: 10/9/2024
On September 19, 2024, CMS announced mandatory off-cycle SNF revalidations will start on October 1, 2024, and conclude at the end of this December. In order to continue to be able to bill Medicare, this will require the completion of an updated CMS provider enrollment form to disclose SNF ownership as well as ownership of “Additional Disclosable Parties” (ADP). This impacts 100% of SNFs. Letters will be sent out between October 1, 2024, and the end of the year, with 90 days to complete.
ADVION has prepared a Provider Enrollment Off-Cycle Revalidation Brief which we are sharing to help break down the new requirements.
Details of Requirement:
- SNFs should expect to receive a letter from their MAC prior to the end of year.
- Providers will have 90 days to respond to the letter and submit the required information into the PECOS system.
- This change will impact every SNF, regardless of their size or ownership.
- The new provider enrollment form must be used for the following provider enrollments effective October 1, 2024:
- Initial Enrollment
- Revalidations
- Reactivations
- Change of Ownership (CHOW)
Note: CMS has recommended that providers seek legal counsel to interpret the new reporting requirements.
Additional Disclosable Party:
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 SNFs 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.
- Provides management or administrative services, management or clinical consulting services, or accounting or financial services to the facility.
The Point Is: This new form is now 20 pages long, compared to the previous 14-page form, and requires in-depth information not only on SNF ownership but for all Additional Disclosable Party’s (ADP). QRM is preparing the ADP portion for our organization should our clients be in need. Each SNF must be on the lookout for this CMS requested information and be prepared to submit within the 90-day timeframe to avoid disruption in their ability to bill Medicare. Please let us know if we can be of additional help.
