The Centers for Medicare & Medicaid Services (CMS) extended the previous deadline of May 1, 2025 to August 1, 2025, for skilled nursing facilities (SNFs) to provide ownership and management information as well as information about other parties with which the SNFs are associated and the ownership structures of those parties. This new deadline provides welcome relief to SNFs as they identify and obtain CMS-mandated information, particularly related to certain “additional disclosable parties” (ADPs).
SNFs, like other providers and suppliers, are required to disclose various ownership and management information on initial enrollment, on revalidation or reactivation, and for changes in ownership. CMS subsequently expanded the information SNFs were required to report effective October 1, 2024, to include:
- All Governing Body Members: SNFs that are corporations must disclose all Board of Directors members. SNFs must now also report all members of their governing body, regardless of business type (e.g., LLC, corporation, etc.);
- All Owners of an LLC: All individual and organizational owners of an LLC must be reported regardless of percentage of ownership;
- All Trustees: A trustee can be a person or entity. The trustee’s beneficiaries are not reported unless they qualify for disclosure under another category (e.g., managing employee); and
- All ADPs: ADPs can be any person or an entity that:
- exercises operational, financial, or managerial control over the SNF or any part thereof;
- provides policies or procedures for any of the SNF’s operations;
- provides financial or cash management services to the SNF;
- leases or subleases real property to the SNF, or owns a whole or part interest equal to or exceeding 5 percent of the total value of such real property; or
- provides management or administrative services, management or clinical consulting services, or accounting or financial services to the SNF.
There are additional reporting requirements for disclosing persons or entities within an ADP depending on the ADP’s business type (e.g., corporation, LLC, general or limited partnership, or trust).
More information about these reporting requirements are found in Attachment 1 of Form CMS-855A.
Should you have any questions regarding the above, or require assistance with meeting these CMS requirements, please contact the authors, the Garfunkel Wild attorney with whom you regularly work, or contact us at [email protected].