Inquiring Minds Want to Know, and So Does CMS – Understanding New Requirements for Ownership and Additional Party Disclosures in Medicare Enrollment and Revalidations

This session will explain new requirements imposed for Medicare enrollment and revalidation imposed by CMS’s October 1, 2024, changes to the CMS-855A form. The speakers will outline new requirements that all skilled nursing facilities (SNFs) disclose more detailed ownership information (both operations and real estate), as well as “additional disclosable parties”. This newly reported data will be collected through a new “SNF Attachment” that will now be part of the CMS-855A. The speakers will also discuss various sub-regulatory questions and answers that CMS has provide since the rollout of the new requirements. The presentation will also analyze various risks the public disclosure of this information may pose to providers. At the conclusion of the session, participants will achieve the following objectives:

• Understand new CMS reporting requirements for SNF CHOWs, CHOPs, revalidations, reactivations, and changes of information
• Gain insights into the mandatory off-cycle SNF revalidation process and implications for non-compliance
• Understand CMS’s possible policy motivations for the changes and the publishing of all data on its public website, and the various risks from that public disclosure

Other Speakers: 

Paula Sanders, Post & Schell PC

For more information, view the agenda.