SNF Off-Cycle CMS-855A Reporting Deadline Suspended Indefinitely

Key Takeaways

• CMS has paused the January 1, 2026, Medicare revalidation deadline for skilled nursing facilities, with a new compliance date to be announced.
• Existing reporting obligations remain in place for SNFs already in the revalidation process. Those SNFs must still respond to any CMS requests for additional information by CMS’s deadlines.

Mandatory Medicare reporting for skilled nursing facilities (“SNFs”) has been suspended indefinitely.¹ The Centers for Medicare and Medicaid Services (“CMS”) has issued formal guidance confirming that the January 1, 2026, off-cycle provider revalidation deadline is paused and a new compliance date and additional information will be provided in future updates. The CMS announcement is available here.

Importantly, CMS has not altered the underlying reporting requirements. Providers who have already submitted their CMS-855A information and have received requests for additional information must continue to respond by stated deadlines.

Industry stakeholders view this deadline suspension as a meaningful step toward easing administrative burdens while CMS works to address outstanding systems concerns and clarify next steps. Providers have struggled with timely compliance, especially given numerous reports of implementation and administrative challenges and technical issues with the CMS PECOS provider enrollment system.

For more information, please contact Hedy Rubinger, Alexander Foster, or Maggie Callahan.

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[1] As a reminder, CMS required the new “Attachment 1” to the Form CMS-855A to be used for SNF enrollment purposes on October 1, 2024. At the time, CMS announced that all SNFs would take part in off-cycle revalidations so that the agency could collect Attachment 1 information from all providers, anticipating this to occur in late 2024. However, CMS subsequently issued three deadline extensions, most recently to January 1, 2026. Previous AGG Bulletins on developments related to the reporting requirements are available here: CMS Releases Update to CMS-855A Enrollment Form With Significant Increase in Disclosure Requirements for SNFs; SNF Off-Cycle CMS-855A Reporting Delayed to August 1, 2025; and SNF Off-Cycle CMS-855A Reporting Delayed to January 1, 2026.