On July 17, 2025, CMS once again extended the deadline for submission of the mandatory Medicare provider off-cycle revalidation applications for skilled nursing facilities (SNFs). The new deadline has been extended from August 1, 2025 to January 1, 2026, and while the extension offers additional breathing room for providers, the scope of required information remains unchanged.
Revalidation Application Preparation Steps
Here are some practical steps providers should consider to help comply with the requirements:
- Submit your application sooner rather than later. Gathering the necessary documentation may be a time-intensive process. The Medicare Administrative Contractors (MACs) are likely going to be deluged with submissions from the more than 15,000 SNFs nationwide. Provider applications submitted well in advance of the deadline will not only allow the MAC to review the submission earlier but will give the provider time to submit any requested corrections.
- Understand what an additional disclosable party (ADP) is and is not. CMS has generally clarified the type of entities/individuals that are considered ADPs, but with the caveat that not all scenarios can be anticipated. CMS has stated that if in doubt, providers should include that entity or individual in the application. The guidance from the update on May 9, 2025 included clarifications on ADPs and reporting of mortgage interest, among other items. Additional information and instructions can be found in CMS’ recent subregulatory guidance from July 23, 2025.
- Make sure to tell your story clearly. Showing the connection between the SNF’s operating entity, the ownership of the building and property, and the various ADPs is central to the intent of the final rule regarding SNF ownership transparency. Making sure the required organizational charts, including that of the SNF’s “managing employees,” match the information contained in the application itself, will typically help the MAC better understand the various relationships, allowing a quicker review and approval of the revalidation.
How Forvis Mazars Can Help
While the outlined steps above can provide a solid foundation for your revalidation process, certain aspects may be unclear. If you need assistance interpreting the requirements or completing your revalidation application, the Senior Living & Long-Term Care team at Forvis Mazars can help you prepare for what’s next. Connect with us today to see how we can assist you with completing and submitting your application.