Jaya White and Kiel Zillmer Write Article for McKnight’s Long-Term Care News About Revalidation Process for Skilled Nursing Facilities
Quarles & Brady Health & Life Sciences attorneys Jaya White and Kiel Zillmer authored an article for McKnight’s Long-Term Care News about the steps skilled nursing facilities must take to adhere to new ownership-related disclosure requirements from the Centers for Medicare & Medicaid Services (CMS).
CMS extended the deadline for revalidation from the previous May 1, 2025, to August 1, 2025. While the additional time is a relief for facilities that have not yet submitted their revalidation application, White and Zillmer noted there’s plenty of work to be done prior to the new deadline. White is a Chicago-based partner and national co-chair of the firm’s Long-term Care team; Zillmer is an associate in Milwaukee.
An excerpt from the article:
Because of the new and more voluminous disclosure requirements discussed above, SNFs that have not yet filed their revalidation applications should promptly begin to identify and collect all additional information needed to complete their filings by the Aug. 1 deadline.
A critical step: reach out to all ADPs to ensure SNFs get all the information they need from those parties to populate the SNF Attachment for each required entity and individual.
CMS expects “maximum feasible efforts” to obtain required information — even if some data proves difficult to secure. In such cases, SNFs should document outreach attempts and notify their Medicare Administrative Contractor of any missing details. SNFs should also consider engaging legal counsel experienced in the Medicare enrollment and revalidation process to advise on any material issues that represent significant impediments to completion of the SNF Attachment.