CMS Issues Updated Guidance for Mandatory Off-Cycle Provider Enrollment Revalidations (SNF)

The Centers for Medicare and Medicaid Services (CMS) recently posted another update to its sub-regulatory guidance for the SNF Mandatory Off-Cycle SNF Provider Enrollment Revalidation process. The update includes four changes, which are noted in italics: 

• Section (VI)(G) concerning pharmacist consultants: Clinical Consulting Services (CCS) includes pharmacist consultants. 
• New FAQ #15 – Is the current off-cycle revalidation effort limited to Medicare, or does it apply to Medicaid, too? A: The current effort is restricted to Medicare. We will furnish information about the Medicaid aspects of our SNF ownership disclosure initiative in the future. 
• New FAQ #16 – If we have a change of information (COI) to report, do we have to pay the application fee required under 42 CFR § 424.514? A: The only instance when a COI requires an application fee is if it involves the addition of a practice location. 
• New FAQ #17 – What do we list as an ADP’s effective date? A: The ADP effective date is the date on which the relationship between the SNF and the ADP commenced.