The Centers for Medicare and Medicaid Services (CMS) has updated important guidance tied to skilled nursing facility (SNF) enrollment and revalidation.

According to a breakdown by Dan Ciolek, associate vice president of therapy advocacy, American Health Care Association/National Center for Assisted Living, the most important guidance includes:


1. CMS updated the section regarding the suspended application submission due dates for all SNFs (I)(C).

• SNFs that (1) have not yet submitted their revalidation applications or (2) had their revalidation applications rejected and have not submitted a new one are still required to submit said applications. However, they may wait to do so until after CMS announces a new due date. MACs will continue to process incoming and pending revalidation applications and make determinations thereon. SNFs that have revalidation applications pending with their MAC can still expect to receive determination letters over the coming months.
  
  

2. CMS added a Q&A indicating that providers that have submitted revalidation applications must still meet the 30-day response time for providing additional information to the MAC.

Q30: Does the submission deadline suspension mean that I need not respond to the MACs’ request for clarifying/missing data regarding my pending application?

A: No. The deadline suspension only applies to SNFs that: (1) have not yet submitted their revalidation applications; or (2) had their previously submitted revalidation application rejected or returned and are required to resubmit one. It does not apply to pending revalidation applications. Thus, if the MAC requests that the SNF furnish additional information regarding data on the latter’s revalidation application within 30 days of the request, the 30-day timeframe must be met.

3. The addition of a new section addressing longstanding required provider enrollment data (non-SNF attachment data).

(VI)(H). Other Application Information

CMS reminds SNFs that all required data on the application (not merely that listed in section 1124(c)) must be furnished and all other requirements completed. This can include, for instance, site visits, fingerprinting, supporting documentation regarding licensure, practice location data, section 1124(a) information (including SNF medical director and administrator data), etc. Even if the SNF successfully furnishes the section 1124(c) data, the application may still be rejected or denied if other requirements are not met (e.g., the SNF (which is a corporation) failed to report to its directors as required under section 1124(a)).

Questions or comments? Contact Patrick Connole at pconnole@parkplacelive.com.