Nursing Home Off-Cycle Revalidations Suspended
(Dec. 9, 2025) The Centers for Medicare and Medicaid Services (CMS) has confirmed to LeadingAge the indefinite suspension of the requirement that nursing homes complete the off-cycle revalidation process by Jan. 1, 2026. Members will recall that the off-cycle revalidation process required all Medicare-certified homes, whether they had reached the date of their periodic Medicare revalidation or not, to submit the expanded form CMS-855A by a single, prescribed date. The original deadline of May 1, 2025 had been previously delayed to Aug. 1st and then to Jan. 1, 2026. At this point in time, providers that have not started the process should await further instruction.
The new 855A form includes a lengthy attachment that requires nursing homes to provide significant detail on any entity that has operational, financial, or managerial control over the facility; provides policies or procedures for any of the operations of the facility; or provides financial or cash management services to the facility. The lack of clarity on the scope of the “additional disclosable parties” (ADPs) that homes needed to report made the process especially challenging. Elimination or simplification of this requirement was part of our Medicare regulatory relief recommendations to CMS.
Please note that while the January deadline is no longer in effect, the provision remains a statutory requirement. That may well mean that nursing home providers will need to submit the additional information at a later date or as part of their periodic recertification. For those seeking insight on completing the new form 855A successfully, the LeadingAge Nursing Home Network still intends to host a special meeting on Dec. 18th at 2 p.m. ET for members to share insights about what has worked and what has not worked in submitting these off-cycle revalidations. Nursing Home Network members will receive call details via email. LeadingAge members who are not yet signed up for the Nursing Home Network can register here.
The Medicare Administrative Contractor (MAC) for NYS has not made any announcement regarding the change yet, but we expect CMS to provide additional guidance in the coming days. We will share that when available.
Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841