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CMS forced to delay nursing home revalidation deadline with 80% unable to comply

Written on Apr 18, 2025

The Centers for Medicare & Medicaid Services (CMS) has again delayed its mandatory provider revalidation program for nursing homes, this time giving providers until Aug. 1 to report far more organizational ties than were previously required. 

The American Health Care Association (AHCA) confirmed the delay April 15, with word that CMS was expected to formally update the deadline via the agency’s Medicare Learning Network website “soon.” 

National provider organizations have indicated that only about 20% of the nation’s nearly 15,000 nursing homes had completed the lengthy reporting process, despite a looming deadline of May 1. 

CMS had already pushed back the deadline, which had been broken into three groups with the earliest reporting starting Dec. 1, 2024. Some providers had just 90 days to comply at that time. The extension to May 1 for all providers conceivably allowed enough time to complete a key form, 855A, and a special skilled nursing facility attachment for each reportable party. 

But provider advocates said subregulatory guidance continued to be unclear on several key points, leaving them to guess as to how to comply. The revalidation FAQs, including details about which employees and partners must be included, continue to be updated by CMS, with changes as recent as April 9. Some vendors also have been reluctant to share the kind of corporate details providers need to report about them, given that CMS plans to post the information publicly in the future. 

AHCA had asked CMS to pause the requirement to allow more time given the extent of the reporting and to address ongoing provider questions. 

While providers typically have to report ownership structures and investor details at a change of ownership or because of other specific circumstances, every federally funded U.S. nursing home was called to report this time around to comply with new CMS regulations geared at increasing transparency into ownership, operational control and related parties. 

The regulations have in some cases forced providers to go from reporting five or 10 management or ownership roles to more than a hundred, including information on the ownership structure of vendors and other partners who provide clinical or staffing support. 

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