Off-Cycle Medicare Enrollment Revalidation: Reminder for Nursing Homes

(April 8, 2025) LeadingAge NY nursing home members are reminded that the deadline for off-cycle Medicare enrollment revalidation is May 1, 2025. As a result of regulations promulgated last year, nursing homes are required to submit a new Centers for Medicare and Medicaid Services (CMS) Form 855A. The new form requires the disclosure of extensive information regarding the ownership and control of the facility and of various entities and individuals that provide the facility with real estate, clinical consulting, financial services, and other operational and administrative services.

The new form and related revalidation process arise out of regulations aimed at promoting greater visibility into the ownership and control structures of for-profit nursing homes. Although aimed at private equity investors, real estate investment trusts, and chains, the disclosure requirements apply to not-for-profit and government-sponsored facilities as well.

The CMS Medicare provider enrollment webpage notes that the online Provider Enrollment, Chain, and Ownership System (PECOS) does not reflect the off-cycle revalidation schedule. Nursing homes should not assume that they have fulfilled the requirement based on the PECOS schedule.

More information about the off-cycle revalidation schedule, including links to the form and guidance documents, is available here. LeadingAge National has made available a recorded webinar on completing the new form.

Contact: Karen Lipson, klipson@leadingageny.org