CMS Extends Off-Cycle Revalidation Deadline
(July 22, 2025) As reported to members on July 16th, the Centers for Medicare and Medicaid Services (CMS) announced that the agency was delaying the deadline for Medicare off-cycle revalidations (i.e., submission of Form 855A) until Jan. 1, 2026. This extends the current Aug. 1st deadline by five months. The guidance document with the updated due date is here.
The off-cycle revalidation process, which can be quite time-consuming, requires all Medicare-certified nursing homes to submit the revised Form CMS-855A, which since October 2024 contains a new, lengthy, nursing home-specific appendix requiring the disclosure of detailed information regarding facility governance, ownership, operations, real estate, as well as Additional Disclosable Parties (ADPs). These may include vendors of various services provided to the facility.
Please note that while Form 855A is also used for new provider Medicare enrollment as well as five-year, provider-specific “on-cycle” revalidations, ALL Medicare-certified nursing homes must complete this off-cycle revalidation by the single due date. This process is separate and apart from the “on-cycle” Medicare revalidations that providers must perform every five years based on a facility-specific timeline. An article from LeadingAge National provides key information and links to recent educational webinars that are available to purchase and view on demand.
The form itself is here (the section relevant to off-cycle revalidation submissions starts on p. 52), the most recent guidance document with Frequently Asked Questions (FAQs) (updated in May 2025) is here, while background information is here and some helpful resources on completing the form are here. Questions are being fielded at SNFDisclosures@cms.hhs.gov and by Medicare Administrative Contractors (MACs) (National Government Services for NYS). The form is submitted through the Medicare Provider Enrollment, Chain, and Ownership System (PECOS).
Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841