2026 SNF Rule Changes: How New CMS 855A Ownership Disclosures Impact Billing

Medicare billing depends on more than accurate codes and timely claims. It begins with correct and complete enrollment information. As part of the 2026 SNF rule changes, CMS has strengthened transparency around ownership and control by updating the CMS-855A requirements, making enrollment compliance a critical factor for continued reimbursement. The CMS-855A, once seen as a routine administrative form, now plays a central role in determining whether skilled nursing facilities can bill Medicare without interruption.

These updates are already in effect and require immediate attention. The revised CMS-855A became effective on October 1, 2024, and CMS has set January 1, 2026, as the deadline for SNFs to complete off-cycle revalidation using the expanded ownership disclosures and the new SNF attachment. This blog explains what has changed and how these requirements directly impact medical billing and coding.

Why CMS Updated the 855A Ownership Disclosure Requirements

CMS changed the 855A form to increase transparency and accountability regarding the ownership and control of skilled nursing facilities. Over time, CMS found that complex ownership structures and undisclosed relationships made it difficult to clearly identify who was responsible for facility operations and Medicare billing. As a result, incomplete information limited CMS’s ability to prevent fraud, improper payments, and compliance risks. Therefore, the updated 855A requires SNFs to disclose detailed ownership and control information so CMS can better track responsibility and oversight.

Also, this change helps ensure that billing privileges are granted only to facilities that meet Medicare’s integrity standards. Therefore, the revised form strengthens program oversight while promoting trust and clarity across the SNF enrollment and billing process.

Key Changes to the CMS-855A for SNFs

CMS made targeted updates to the CMS-855A form to expand the amount of ownership and control information that skilled nursing facilities must report. These changes include:

• SNF-Specific Ownership Attachment

CMS added a separate SNF-specific attachment to the CMS-855A that focuses entirely on ownership, control, and managing relationships. This attachment standardizes how information is reported, which helps reduce gaps and inconsistencies. As a result, SNFs must complete this section in addition to the core 855A form.

• Expanded Ownership and Control Reporting

SNFs are now required to disclose a broader range of individuals and entities with ownership or control interests. This includes direct and indirect owners, as well as individuals or organizations that exercise managerial authority. Therefore, facilities must look beyond surface-level ownership and identify all parties that influence operations or financial decisions.

Related Parties and Management Entities

CMS now requires more transparent reporting of related parties, including management companies, consulting firms, and affiliated organizations. These disclosures explain how services are provided and who is responsible for key operational functions. As a result, CMS can better understand relationships that may affect billing and compliance.

• Complex Ownership Structure Transparency

Facilities with layered or multi-entity ownership structures must now clearly outline each level of ownership. This change ensures that CMS can trace ownership from the facility level to the ultimate controlling parties. Consequently, SNFs must maintain accurate ownership records that align with what is submitted on the form.

• Broader Reporting Events

The updated requirements apply not only to initial enrollment but also to revalidation, reactivation, and reported changes in ownership or control. Therefore, SNFs must treat ownership disclosure as an ongoing responsibility rather than a one-time task. This approach helps keep CMS records current and reliable over time.

• Accuracy and Accountability Expectations

CMS has placed greater emphasis on the accuracy and completeness of all reported information. In fact, incomplete or incorrect disclosures can now lead to processing delays or adverse enrollment actions. As a result, SNFs are expected to review submissions carefully and ensure all required information is fully documented before filing.

Impact of CMS-855A Ownership Changes on Medical Billing and Coding

Although the CMS-855A updates focus on enrollment and ownership transparency, they have a direct and practical impact on medical billing and coding for skilled nursing facilities. As Medicare billing is tied to active and compliant enrollment, any issue with ownership disclosures can immediately affect claim submission, payment, and audit exposure. As a result, billing and coding teams must align their workflows with these updated requirements.

• Enrollment and Claim Submission

Accurate CMS-855A disclosures are now more critical to maintaining active Medicare enrollment. If ownership or control information is missing or inconsistent, CMS may delay or deny revalidation. As a result, claims submitted during this period may be rejected or placed on hold, even when coding is technically correct.

• Claim Denials and Payment Delays

Incomplete or inaccurate ownership reporting can lead to enrollment-related denials. As a result, billing teams may see an increase in rejected claims that are unrelated to coding errors. This creates additional rework, longer accounts receivable cycles, and delayed reimbursements.

• Related-Party Billing Oversight

With clearer visibility into related parties and management entities, CMS can more easily identify billing patterns across affiliated healthcare organizations. In fact, claims involving shared services, contracted providers, or management companies may be subject to closer review. Therefore, coding teams must ensure that services are clearly documented, correctly attributed, and billed under the appropriate entity.

• Documentation and Medical Necessity

Ownership transparency supports broader CMS efforts to strengthen program integrity. As a result, claims may be reviewed more closely for medical necessity and completeness of documentation. Coders must ensure that clinical records fully support reported codes, especially for higher-acuity or longer-stay services.

• Audits and Compliance Reviews

It is important to note that enhanced ownership disclosures allow CMS and contractors to connect audit findings across commonly owned facilities. Therefore, billing and coding errors identified at one location may increase scrutiny across the entire healthcare organization. This makes consistent coding practices and standardized documentation essential.

• Team Coordination

As enrollment compliance now directly affects billing outcomes, stronger coordination across departments is required. Billing and coding teams must be informed of ownership changes and enrollment status updates. As a result, facilities can reduce avoidable denials and protect revenue continuity.

• Revenue Cycle Stability

When ownership information is accurate and up to date, SNFs can maintain uninterrupted billing privileges. This stability allows billing and coding teams to focus on accuracy and efficiency rather than reactive claim corrections. Therefore, proactive compliance supports cleaner claims, faster payments, and lower audit risk.

Role of 24/7 Medical Billing Services in 2026 SNF Rule Changes

As skilled nursing facilities prepare for the 2026 CMS-855A ownership disclosure requirements, 24/7 Medical Billing Services supports providers by connecting enrollment compliance with effective billing and coding practices. The team closely monitors Medicare enrollment status, ownership updates, and revalidation timelines to help prevent claim interruptions caused by administrative gaps. Simultaneously, billing and coding workflows are aligned with current CMS requirements, ensuring that claims are submitted accurately and only under fully compliant enrollment records. This proactive approach helps SNFs avoid preventable denials and maintain steady cash flow.

Additionally, 24/7 Medical Billing Services helps facilities maximize the benefits of compliant medical billing and coding by strengthening documentation quality and audit readiness. In fact, coders ensure that clinical records clearly support reported services, whereas billing specialists apply payer-specific rules with precision, especially for related-party and affiliated-entity services. As a result, SNFs benefit from cleaner claims, faster reimbursements, and reduced compliance risk, allowing staff to focus on patient care rather than on revenue disruptions.

FAQs

Does the updated form apply to new and existing SNFs?

It applies to both newly enrolling facilities and those undergoing revalidation.

Is there a separate attachment for SNFs on the CMS-855A?

The SNF-specific attachment collects detailed information on ownership and control.

Can a facility submit the form electronically?

The form can be submitted via PECOS or on paper, as required.