Skilled nursing facilities (SNFs) and other institutional healthcare providers that plan to bill Medicare are required to publicly disclose their ownership and management information, per requirements of the Social Security Act and the Medicare program. In efforts to collect a more complete background on these organizations, and the individuals that own and oversee them, additional requirements for SNFs were added in a Final Rule that was published in November 2023. As of October 1, 2024, all SNFs are now required to disclose other parties they are associated with, as well as ownership structures of those named parties. This information is to be submitted using the revised Form CMS-855A with the required SNF attachment. The new SNF Attachment replaces Sections 5 and 6 of the Form. The deadline for all SNFs to submit under the new requirements has been postponed several times, and as of December 9, 2025, it has been indefinitely suspended. While this is a welcomed relief, the reality is that the policy is not going away and providers need to understand the requirements and continue collecting data so the information is ready to submit once further guidance is provided.
Does this apply to your SNF?
SNFs are required to submit the required documents if:
They are enrolling in Medicare for the first time
They need to revalidate Medicare enrollment
They need to reactivate Medicare enrollment
They need to report a change of ownership (CHOW)
They are voluntarily terminating their Medicare billing privileges
Their previously submitted application(s) are still pending as of October 1, 2024
What does your SNF need to report?
The new attachment form expands on the information that SNFs will have to report. The data is separated into two sections: organizations (19 questions) and individuals (23 questions). The applicable section must be fully completed for each organization or individual that must be reported. A report must be submitted for all the following:
All members of the governing body (regardless of entity type)
Officers, directors, members, partners, trustees and managing employees (depending on entity type (LLC, corporation, etc.)
All owners of LLCs (no percentage threshold anymore)
Trustees (if SNF is organized as a trust)
Individuals/entities meeting the additional disclosable party (ADP) definition, including those who:
Hold operational, financial or managerial control
Provide financial, administrative, operational or clinical consulting services
Lease or sublease real estate to the SNF
Own 5% or more interest in the SNF real property
For each ADP, SNFs must disclose:
Description of the relationship with the ADP
Organizational structure of the ADP
Any overlapping interests with the SNF or other ADPs
Additionally, if there are changes to key individuals or entities after the information is submitted, it must be reported within 30 days. This includes changes to owners, managing employees and officers. Any other changes to the data must be reported within 90 days.
How can your SNF prepare?
Following these best practices can help your facility navigate the significant changes ahead:
Understand the relevant types of individuals and entities that must be reported as ADPs
Accounting firms, management firms, staffing agencies, clinical consultants and therapy companies must be disclosed
EHR vendors, technical support, custodial services, equipment vendors, labs and pharmacies do not need to be disclosed
When unsure, seek the assistance of a professional adviser such as Richter who has experience with Medicare enrollment and revalidation processes
Proactively work with contractors, service providers and other ADPs to obtain necessary information
If the ADP does not cooperate with the request for information:
Use other resources (Internet search, existing records, etc.) to try and acquire the information
Document all efforts to obtain the required information from the ADP, including dates and methods of communication
Notify the Medicare Administrative Contractor (MAC), with a summary of the situation
Work ahead of the submission deadline, especially if you are required to report large volumes of individuals or organizations
Until a new deadline is announced, SNFs should remain prepared to comply with the rules that have already been established. Do not put your Medicare beneficiaries at risk by waiting until the last minute to ask for help. The experienced team at Richter can assist with any new or existing Medicare applications. We support skilled nursing facilities throughout the U.S. with fully customized, leading-edge consulting services in all areas of operation. To learn more about our comprehensive solutions, contact us here or call us at 866.806.0799.
