Nursing Home News 2025Dec12

Kierstin Reed • December 12, 2025

SNF Off-Cycle Revalidations Suspended Indefinitely

LeadingAge confirmed with the Centers for Medicare & Medicaid Services (CMS) on December 8 that the Skilled Nursing Facility (SNF) Off-Cycle Revalidation, required by January 1, 2026, has been indefinitely suspended. It is important to note that only the January 1 (“off-cycle”) compliance date has been suspended. CMS emphasized in communication via the SNF Disclosures HelpDesk that the “initiative” itself has not been suspended and in fact, as LeadingAge notes, is statutorily required. This may mean that providers will continue to be required to submit information on additional disclosable parties during routine revalidations. LeadingAge is seeking more information. In the meantime, providers should look for this announcement in CMS’s upcoming MLN Connects Newsletter.

Peer-to-Peer Support for Off-Cycle Revalidation

Although CMS has been indefinitely suspended, LeadingAge has received an increased volume of questions regarding submission of the Skilled Nursing Facilities (SNF) Off-Cycle Revalidation (Form CMS-855A). LeadingAge will continue with the special meeting for the Nursing Home Network to discuss and support members. We are hearing frustration from members at the perceived lack of support from CMS and the Medicare Administrative Contractors (MACs) at addressing these questions, so let’s try to help each other. The LeadingAge Nursing Home Network will host a special meeting on December 18 at 2pm ET for members to ask each other questions and share insights about what has worked and what has not worked in submitting these off-cycle revalidations. Please note, this call is not meant to be interpreted as expert advice or guidance. The purpose of this peer-to-peer forum is simply to connect members and help us leverage our LeadingAge network. Nursing Home Network members will receive call details via email. Not yet a member of the Nursing Home Network? Register here. Email Jodi Eyigor jeyigor@leadingage.org with questions.

Winter/Holiday Life Safety Code Reminders

State Fire Marshall has provided reminders on heating during extreme weather in health care facilities. Facilities should consider creating a plan to address the loss of heating systems within the building. Guidance can be found here.

It is also the time of year when we need to provide reminders to residents and families on what decorations are safe to display at the facility. Guidance on these requirements can be found here


QAA Payment Deadlines: MLTC will begin strongly implementing the 45 days of the quarter ending deadline for payments to be received. DHHS will automatically suspend Medicaid payments until QAA and any associated late penalties are received. Because the Medicaid rates already include the QAA component they will no longer continue to make payments if assessed dues are unpaid. This is Standard Operating Procedures and facilities may receive penalties as allowed by Nebraska Revised Statute 68-1925. The Medicaid suspension will be lifted immediately upon receipt of the QAA form and any amounts due. However, it typically takes 5-10 business days for any claims that were in process to be manually worked before new claims can be processed. Date payments are received shall be the postmark date on or before the 30th to be considered on time. This must be for the USPS postmark, not the postage meter. After the due date, they will send notices to any facilities that have not submitted the form and payment. Please be sure the envelope is addressed exactly to ensure proper delivery. 

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