Providers Required to Submit Managing Employee Information to Provider Enrollment Records Immediately

On February 8, 2024, the Centers for Medicare and Medicaid Services (CMS) MLN Connects newsletter,  provided clarification to providers regarding the status of and skilled nursing facility (SNF) medical directors and administrators as managing employees for Medicare provider enrollment. According to the newsletter, these roles are consistently considered managing employees, necessitating their inclusion in provider enrollment documentation. Providers were urged to ensure the reporting of all current managing employees, emphasizing the immediate reporting of any previously unreported medical directors or administrators.
CMS further communicated, via an email to AHCA/NCAL, that the required information could be submitted through a CMS-855A change of information (COI) submission. SNFs were advised to access information regarding the COI process for reporting SNF medical directors and administrators either through the CMS enrollment website or by reaching out to their local Medicare Administrative Contractor (MAC).
Prior to this notification, ambiguity existed regarding the method of reporting these individuals—whether it should be through a COI submission or during the subsequent revalidation period. However, this notice clarified that providers should not postpone reporting until revalidation and should instead promptly submit any missing medical director or administrator details through the COI submission process.
Furthermore, in the CMS final rule dated November 17, 2023 (CMS-6084-F), titled "Disclosures of Ownership and Additional Disclosable Parties Information for Skilled Nursing Facilities and Nursing Facilities; Medicare Providers' and Suppliers' Disclosure of Private Equity Companies and Real Estate Investment Trusts," CMS amended the regulatory definition of "Managing Employee" in 42 CFR 424.502 to explicitly encompass hospice or skilled nursing facility administrators and medical directors.
Providers were directed to consult the Medicare Program Integrity Manual regarding updates to the CY 2024 Home Health Prospective Payment System, particularly the MLN Matters article, for comprehensive information on changes to the Medicare Program Integrity manual. This update includes revisions to the definition of "managing employee," which also affects SNFs.
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