CMS Revised Form CMS-855A: Key Changes for Skilled Nursing Facilities
A substantially revised version of Form CMS-855A was issued by the Centers for Medicare & Medicaid Services (CMS). According to the new guidelines, skilled nursing facilities will be expected to use the revised form for all initial enrollment, revalidation, reactivation, and changes of ownership applications. The new form is effective for SNFs as of October 1, 2024.
Requirements for Skilled Nursing Facilities in Form CMS-855A
- Attachment 1 is the major amendment in the new edition of Form CMS-855A, which replaces Sections 5 and 6 from the earlier version of the form exclusively for SNFs.
- The new version of the attachment now requests quite a high level of detailed information about the ownership and operating arrangements of the SNFs. These include disclosures about governing body members, officers, directors, trustees, and managing employees, as well as other disclosable parties (ADPs) exercising control over the facility or providing management, financial, and real estate-related services.
- The amended version would eliminate the 5% ownership threshold for disclosure in LLCs and retain it for corporations.
- SNFs also need to give organizational charts of the relationship among those individuals and entities disclosed if some entities fall below the ownership threshold.
Reporting Requirements for ADPs
CMS identified some categories of entities and individuals that must be reported under Attachment 1, provided that they qualify as ADPs. Some of those categories are as follows:
- Control Entities: Any party exercising operational, managerial, or financial control over the SNF. This includes entities responsible for developing or enforcing policies and procedures, or parties overseeing specific parts of the SNF’s operations (e.g., medical records or dietary services).
- Real Estate Entities: Entities that lease or sublease the real property to the SNF or otherwise have an ownership interest in the real estate property.
- Management Organizations: These are organizations that provide management, administrative, or consulting services to the SNF.
CMS has also reemphasized timely and accurate reporting. New or updated SNF Attachment 1 information shall now be reported within 30 to 90 days of any changes.CMS announced off-cycle Medicare revalidation for SNFs, scheduled to occur between October and December 2024. These updates signify continuous efforts by CMS to increase transparency and oversight at SNFs.
For further information, SNFs should consult CMS’ official guidance on the updated Form CMS-855A and prepare for the upcoming off-cycle revalidation process, which is expected to take place through the end of 2024.
