On December 11, 2025, the Centers for Medicare & Medicaid Services (“CMS”) extended the due date indefinitely to complete and submit the new Form CMS-855A Skilled Nursing Facility (“SNF”) Disclosures Attachment for every SNF.
In its Medicare Learning Network, 2025-12-11-MLNC, CMS formally announced that enrolled SNFs should continue collecting data on ownership, managerial, and related party information and submit their revalidation. However, there is no submission deadline until further notice. Guidance for SNF Attachment on Form CMS-855A, updated December 9, 2025 (“Guidance”), confirms that SNFs that have not submitted their revalidation applications can still do so.
Hall Render’s overview of the Medicare disclosure requirements for SNFs can be found here, here, here and here.
Practical Takeaways
- CMS extended the SNF application submission due date indefinitely. For the time being, there is no submission deadline. CMS will provide additional information in future guidance.
- The Guidance recommends that in the interim, SNFs that have begun working on their SNF applications in the Medicare Provider Enrollment, Chain, and Ownership System (“PECOS”), but have not submitted them, are strongly encouraged to make at least one edit or addition to their pending application every 120 calendar days to help ensure the application is not removed from PECOS for inactivity.
For more information on the reporting and the CMS-855A, please contact:
- Brian Jent at (317) 977-1402 or bjent@hallrender.com;
- Lauren Hulls at (317) 977-1467 or lhulls@hallrender.com;
- Julie Mitchell at (317) 429-3643 or jmitchell@hallrender.com;
- Sean Fahey at (317) 977-1472 or sfahey@hallrender.com;
- Todd Selby at (317) 977-1440 or tselby@hallrender.com; or
- Your primary Hall Render contact.
Hall Render blog posts and articles are intended for informational purposes only. For ethical reasons, Hall Render attorneys cannot—outside of an attorney-client relationship—answer specific questions that would be legal advice.
