CMS Indefinitely Suspends Skilled Nursing Facility Enrollment Revalidation

The Centers for Medicare and Medicaid Services (CMS) has indefinitely suspended its mandatory off-cycle skilled nursing facility (SNF) provider enrollment validation that was previously set to be due by January 1, 2026. This pause responds to concerns expressed by industry associations, including the American Health Care Association and National Centers for Assisted Living (AHCA/NCAL), about the challenges and complexities involved in the revalidation process. The suspension aims to maintain continuity of care while providers continue compliance with ownership transparency and reporting requirements. CMS initially introduced the off-cycle revalidation process in October 2024, requiring skilled nursing facilities to update enrollment information within a 90-day window using a revised CMS-855A form. This updated form captures detailed data on ownership, management, and related-party transactions, reflecting CMS's heightened focus on SNF operations, particularly in the context of private equity and real estate investment structures. Throughout 2025, many nursing facilities struggled to complete revalidation amidst multiple CMS deadline extensions. This indefinite suspension marks the fourth delay by the agency, signaling ongoing operational challenges in meeting the enhanced enrollment requirements. Providers who have already submitted forms and received requests for additional information are advised to comply with follow-up submissions as requested. Current SNF provider enrollment policies remain unchanged, and facilities are encouraged to maintain accurate data on ownership and control to ensure readiness for future CMS guidance. Medicare Administrative Contractors (MACs) are available to provide support for providers encountering system issues or deadline concerns. This CMS action reflects broader regulatory efforts to strengthen oversight of skilled nursing facility ownership transparency and operational control, while balancing providers' capacity to comply and uninterrupted resident care. The developments highlight an ongoing dialogue between regulators and industry stakeholders about optimizing enrollment processes and focusing on meaningful data reporting to protect patients and sustain operational stability in the SNF sector.