Client Alerts & Insights
Off-Cycle Medicare Revalidations for SNFs – Deadline Extended to August 1, 2025
April 21, 2025
Authored By:
On April 17, 2025, the Centers for Medicare and Medicaid Services (“CMS”) announced via a Medicare Learning Network (“MLN”) update that the deadline for submission of mandatory off-cycle Medicare revalidations for skilled nursing facility (“SNF”) providers has been extended to August 1, 2025.
CMS also published updated sub-regulatory guidance on the SNF Attachment to the CMS 855A (dated April 9, 2025), which contains further clarification on certain service provider disclosures (e.g., therapy).
This extension will come as a relief to SNF providers as recent reporting shows less than twenty percent of required off-cycle Medicare revalidations have been submitted for processing.
Despite the extension, we recommend that SNF providers continue working on their revalidation applications to be in a position to submit no later than CMS’s deadline.
Benesch will continue to monitor this matter and further developments with CMS.
For more information regarding the above, please contact a member of the Benesch Healthcare+ Practice Group.
Latest News
Customs Duty Assists: Regulatory Compliance Overview and FAQ
Customs compliance and enforcement defense are high-profile exercises within U.S.-based importers due to the higher-risk regulatory enforcement environment. One of the more complex hot topics facing compliance and legal professionals within importers of record (IORs) is the degree to which “assists” impact dutiable value, and therefore duty burden, in the eyes of U.S. Customs and Border Protection (CBP).
TSA Authorized Representatives—Emerging Practice of Engaging Freight Brokers and Its Practical Implications
Air transportation safety has long been of critical supply chain importance and geopolitical significance, and that role is growing. Supply chain constraints over this decade have driven a need for adaptation, modal diversification and cost containment. To do so, authorized air cargo providers have increasingly explored new ways to add capacity for regulated surface transportation.
Chameleon Carriers—FMCSA’s “Reincarnated” Rule and Enforcement
As the U.S. DOT and its FMCSA ramp up certain elements of domestic enforcement, regulators are utilizing existing laws and regulations that previously were not often invoked. Enforcement of the English language proficiency requirement is one great example.
What’s Old Is New Again: Broker Liability Insulation from the Case Law in the Post-Montgomery Era
The Supreme Court has spoken in its Montgomery v. Caribe Transport decision, and the brokerage sector, and even shipper and motor carriers, are working toward adapting to this “new liability regime.”