SNF Off-Cycle CMS-855A Reporting Delayed to January 1, 2026

The Centers for Medicare & Medicaid Services (“CMS”) has extended the window for skilled nursing facilities (“SNFs”) to file off-cycle Medicare revalidation documents until January 1, 2026. This marks CMS’ third deadline extension for the reporting requirement.

As a reminder, CMS introduced the required “Attachment 1” to the Form CMS-855A to be used for SNF enrollment purposes on October 1, 2024. CMS announced at that time that all SNFs would take part in off-cycle revalidations so that the agency could collect Attachment 1 information from all providers.¹ Initially, CMS announced that off-cycle revalidations would likely take place in October and December 2024. However, CMS subsequently extended the reporting deadline: first to May 1, 2025, then to August 1, 2025, and now to January 1, 2026.

The most recent extension is welcome news to industry stakeholders, given the significant amount of information requested by CMS in the new reporting requirement. The announcement from CMS is available here.

For more information, please contact AGG Healthcare attorneys Hedy Rubinger or Cody Davis.

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[1] Previous AGG Bulletins on developments related to the reporting requirement 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.